EPA 91Q-R-95-006
ENVIRONMENTAL ASSESSMENT FOR THE PROPOSED PRIBILOF ISLANDS
SEAFOOD PROCESSING GENERAL MPDES PERMIT
Prepared by the U.S. Environmental Protection Agency
Region 10, WD-126
1200 Sixth Avenue
Seattle, WA98101
With Technical Assistance From
Science Applications International Corporation
Environmental and Health Sciences Group
1710 Goodridge Drive
McLean, VA 22102
September 1995
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INTRODUCTION
Proposed Action
The U.S. Environmental Protection Agency (EPA), Region 10, is proposing to issue a separate general
National Pollutant Discharge Elimination System (NPDES) permit for seafood processors, both mobile
and shore-based facilities, operating near the Pribilof Islands, Alaska. The general permit (proposed
permit no. AK-G52-POOO) would authorize, subject to the stated limitations, conditions, and
requirements, seafood processing discharges from moored floating or mobile barges and other vessels
discharging through stationary outfalls on St. Paul and St. George islands. In addition, the permit would
authorize discharges from mobile vessels operating within 3 nautical miles of St. Paul, St. George, or
Otter Island, except in the vicinity of critical habitat, as specified. Based on the provisions of the
National Environmental Policy Act (NEPA), EPA has prepared this Environmental Assessment (EA) to
provide the basis for their decision whether to issue a Finding of No Significant Impact (FONSI), or to
prepare an environmental impact statement (EIS) for the proposed action. This EA is consistent with
the NEPA implementing regulations of both the Council on Environmental Quality (40 CFR 1500) and
EPA (implementing regulations for the new source NPDES program 40 CFR 6, subpart F).
Purpose and Need for Action
EPA recently reissued NPDES permit number AK-G52-0000 (60 FR 34991, July 1995), a general permit
authorizing discharges from seafood processors in the State of Alaska. In accordance with NEPA, an
EA was prepared for the statewide general permit and the permit alternatives because it covers new
source facilities. This permit does not, however, authorize discharges to the protected water resources
and special habitats described below.(EPA 1995b).
• Within one nautical mile of a State Game Sanctuary, State Game Refuge, or State
Critical Habitat.
* Within one nautical mile of a National Park, Preserve, Wildlife Refuge, or Wilderness
Area.
* Within three nautical miles of the seaward boundary of a rookery or major hauloutarea of the
Steller sea lion which has been designated as "critical habitat" by NMFS.
• Within one nautical mile of the seaward boundary of a rookery of the northern fur seal during
the period of May 1 through November 15.
• Within one nautical mile of the seaward boundary of a nesting area of a colony of one thousand
or more of the following seabirds during the period of May 1 through September 30: auklets,
cormorants, fulmars, guillemots, kittiwakes, murrelets, murres, puffins, and/or terns.
« In a river designated as wild or scenic under the Wild and Scenic Rivers Act.
Due to increased economic reliance upon commercial fishing and seafood processing within the Pribilof
Islands, following the abolishment of commercial northern fur sea! harvesting by the Federal
government, there was a request from the cities of St. Paul and St. George, during hearings for the
state consistency findings, that EPA exempt the Islands from certain limitations in coverage of the
statewide general permit. The state consistency findings were that temporary permitting provisions
would be made for the Pribilof Islands while an interagency workgroup completes a problem
identification and evaluation process (60 FR 35016). Based on this finding, EPA is proposing to issue
a permit for the Pribilof Islands that will allow.seafood processors to discharge outside an exclusion
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zone of at least 0.5 nautical mile (nmi) radius from areas of special concern during critical nesting and
rookery periods and outside a radius of 3 nmi from Steller sea lion critical rookeries. This differs from
the larger protective radii of the statewide general permit. Limitations in the proposed general permit
are summarized in the following section.
Description of the Proposed Action
The proposed general permit for seafood processing in the Pribilof Islands authorizes the following types
of discharges: seafood processing wastes, except wastes from seafood paste, mince, or meal
processing; process disinfectants; sanitary wastewaters; and other wastewaters specified in the permit,
including domestic wastewater, cooling water, boiler water, gray water (vessels only), freshwater
pressure relief water, refrigeration condensate, water used to transfer seafood to the facility, and live
tank water.
Such discharges are not authorized within the following regions:
• Areas that are likely to have poor flushing, including sheltered water bo'dies such as bays,
harbors, inlets, coves, and lagoons;
• Critical habitats including areas within one-half nautical mile of land owned by the U.S.
Fish and Wildlife Service (USFWS) or the National Marine Fisheries Service (NMFS) for
the protection of northern fur seal rookeries during the period of May 1 through
December land and bird nesting areas and habitat during the period of May 1 through
September 30; areas within three nautical miles of Steller sea lion rookeries or within
0.5 nmi of major haulouts which have been designated as critical habitat by NMFS; and
National Wildlife Refuges.
The proposed permit provides an exception to the limitations on the proximity of discharges to critical
habitats from existing stationary outfalls on St. Paul and St. George Islands. Discharges through
existing stationary outfalls which were previously permitted under the Alaska Seafood General Permit
issued in 1989 are authorized, provided that there is no evidence of wastes on the sea surface or
shoreline, the facilities discharging comply with the sea surface and shoreline monitoring program
during the period of May 1 through December 1, and finfish waste limitations are not exceeded during
the period of May 1 through December 1.
EXISTING CONDITIONS
The following briefly describes the general area of coverage, existing facilities and their discharges,
relevant pollutant discharge standards, and the regional environment.
Description of the Area of Coverage
The Pribilof Islands are located on the Bering Sea shelf approximately 300 miles southwest of mainland
Alaska (Figure 1). St. Paul and St. George Islands are the largest land masses in the Pribilofs (Figures
2 and 3); other islands include Walrus Island and Otter Island. The proposed permit for the Pribilof
Islands will authorize discharges within three nautical miles from mean lower low water (MLLW) of St.
Paul, St. George, Otter, or Walrus Islands, except those within .a protected zone defined as critical
habitat during specified periods. These protected zones and critical periods are discussed in the
previous section of this document.
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WALRUS
ISLAND
(Critical Habitat
lor Staler Sea Lion!
MAP LOCATION
o
OTTER ISLAND
005E
Figure 1. The Pribilof Islands Including Grit1'"' habitat for Steller Sea Lions on Walrus Island.
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East Landing
Sea Lion Rock
(Critical Habitat for Steller Sea Lion)
; Fur Seal Rookery
Fur Seal Hauling
Ground
Critical Habitat for
Nesting Birds
MAP LOCATION
^-Northeast Point
' >/ (Critical Habitat
for Stellar Sea Lion)
Nautical Miles
1/20- 1 2 3 4
Fur seal rookeries and hauling grounds and critical habitat (or nesting birds are not shown to seals.
QQ5E
Figure 2. St. Paul Island Including Protected Marine Mammal and Seabird Habitats.
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[ i Fur Seal Rookery
Dalnoi Point
(Critical Habitat for Stsller Sea Lion)
Fur Seal Hauling
Ground
Critical Habitat for
Nesting Birds
South Rookery
(Critical Habitat for Stellar Sea Lion)
MAP LOCATION
ST. GEORGE ISLAND
Nautical Miles
11/20 1 2 3
Fur seal rookeries and hauling grounds and criltcal habitat for nesting birds are not shown to scale.
005E
Figure 3, St. George Island Including/ cted Marine Mammal and Seabird Habitats.
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Steller Sea Lion
Breeding Activity
(late May-early July)
Northern Fur Seal
Breeding Activity
(May-Nov)
Seabird
Nesting Period
(May-Nov)
Crab Processing
(Jan-Mar; Nov-Dec)
Finfish Processing
(Jan-Aug; Oct-Dec)
Snail Processing
(Jun; Sep-Oct)
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Figure 4, Critical Breeding and Nesting Periods and Seafood Processing Activities.
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Seafood processing discharges from seafood paste, mince, or meal processing are not covered under"
the proposed permit. According to annual reports submitted by facilities operating in the Pribilof Islands
region under the statewide general permit, the majority of processed seafood includes several different
species of crab, along with a smaller quantity of snails and a few species of finfish. The periods of
highest reported processing and related discharges occur from January to March and November through
December, and does not overlap with critical breeding and nesting periods (Figure 4).
Description.of Existing Facilities and Discharges
There are five existing processors within the Pribiiofs region. Two floating and one shore-based
processors maintain outfalls within the East Landing Harbor of St. Paul Island (Figure 2). Of the two
floating processors, one is located in the harbor most of the time, while the other uses the harbor only
for crab processing. The outfalls at East Landing Harbor generally extend approximately 800 ft from
shore and discharge in water depths of 22 ft MLLW. The two remaining operations are floating
processors that utilize an outfall within St. George Harbor, south of Zapadni Bay (Figure 3). The outfall
at St. George extends 400 ft from shore, discharging at depths of 20 to 25 ft. Annual reports
submitted to the EPA by these facilities indicate that the primary species processed were crabs
including opilio, king, hair, and tanner crabs with some halibut, cod, other miscellaneous bottomfish,
snails, and bait squid also processed. Crab processing for both islands occurs primarily from January
through March; some processing occurs in September and from November to December. Halibut
processing generally occurs during summer months (May through August) while cod and miscellaneous
bottomfish may be processed throughout most of the year (Figure 4). In addition to the three outfalls
at East Landing, a fourth outfall serves as a year round sanitary sewer discharge point for St. Paul city.
The waste from the city sewer line receives primary treatment through a community septic system prior
to discharge. Discharges from this outfall are composed of sewage, which may contain industrial
cleaning products or other materials flushed down toilets.
In general, seafood processing facilities may consist of offloading equipment used to transfer catch from
fishing vessel to processor; seafood holding tanks; processing lines; process waste collection systems;
treatment and discharge facilities; storage areas for processed seafood; and support facilities including
electrical generators, boilers, retorts, water desalinators, and office and living quarter space.
Authorized discharges from Pribilof processing facilities include seafood processing wastes (excluding
wastes generated from processing of seafood paste, mince, or meal); process disinfectants; sanitary
wastewaters; and other wastewaters (e.g., domestic wastewater, cooling water, boiler water,
refrigeration condensate, vessel gray water, tank water, and transfer water) (EPA 1995a).
Based on available reports for the existing processors, in general, discharge waste volumes were less
than 100,000 pounds per day, with processing typically restricted to less than six months per year.
Processing waste solids include shell, bones, scales, flesh, skin, and organs with over 70% attributable
to the water content of both fish and crab (EPA 1994c). Crab processing results in a higher inorganic
waste content relative to fish processing due to the large proportion of chitinous shell discarded.
Description of Pollutant Standards and Discharges
The following pollutants may be found in the discharges authorized by the proposed general permit and
are covered under the State of Alaska's Water Quality Standards: floating or suspended solids (total
suspended solids); biochemical oxygen demand.; oil and grease; fecal coliform; pH; temperature; color;
turbidity; and total residual chlorine. In accordance with NPDES regulations the proposed permit
includes a provision that states discharges shall not violate Alaska Water Quality Standards for any of
these aforementioned pollutants. The -following section provides a sumnrfary of the relevant Alaska
Water Quality Standards for these pollutants.
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Total suspended solids (TSS)
State water quality standards maintain that TSS concentrations should not result in scum, soiids,
debris, sludge, or deposits that alone or fn conjunction with other substances or wastes cause the
water to be unfit or unsafe. Further, TSS levels should not cause leaching of -toxic or deleterious
substances; sludge, solid, or emulsion deposits beneath or upon surface waters, within the water
column, in bottom waters, or upon adjoining shorelines.
Biochemical oxygen demand (BOD)
The.applicable State water quality standard states that dissolved oxygen shall be greater than or equal
to 6 mg/L (coastal) or 5 mg/L (estuarine) for a depth of one meter, except when natural conditions
cause this value to be depressed, and shall be greater than or equal to 5 mg/L at any point beneath the
surface (in both coastal and estuarine waters).
Oil and grease
State standards maintain that discharges of oil and grease shall not cause a film, sheen, or discoloration
of the water body or adjoining shorelines; surface waters should be virtually free from floating oils; and
animal fat concentrations should not impart undesirable odor or taste to aquatic life (as determined by
bioassay or organoieptie tests).
Fecal coliform (FC)
The applicable State water quality standard states that the median concentration for fecal coliform
bacteria shall not exceed 14 FC per 100 mL in marine waters.
The State water quality standard for marine waters requires pH to be no less than 6.5 or greater than
8.5, and no more than 0.1 of a pH unit from natural conditions.
Temperature
The State water quality standard for marine waters requires that temperature shall be no more than 15°
Celsius (C) and shall not cause the weekly average temperature to increase more than 1 °C. Normal
daily temperature cycles shall not be altered in amplitude or frequency.
Color
The State water quality standard for marine water coior requires that color not exceed 5 color units.
Further, there should be no interference that would cause water to be unfit or unsafe to use.
Turbidity
The State water quality standard for marine waters limits turbidity to no more than 25 nepheiometric
turbidity units (NTU). In addition, turbidity shall not reduce the depth of the compensation point for
phqtosynthetic activity by more than 10%.
Total residual chlorine (TRC)
State water quality standards require that TRC be no more that 2//g/L for salmonid fish and no more
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that 10 fjg/L for other organisms.
Description of Seafood Processing Effluent
The following provides general information characterizing seafood processing effluent content, including
residual chlorine concentrations, and mass loadings to receiving water bodies. This information is
based on data evaluated in the Ocean Discharge Criteria Evaluation Report (EPA 1994c), covering a
variety of facilities and is categorized by the product most often processed in the Pribilofs (e.g., crab,
bottomfish, and halibut).
Chlorinated disinfectants and other cleansers are often used to scrub and washdown processing
equipment. As previously mentioned, state TRC standards require concentrations of <2plL for
salmonids and
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POTENTIAL EFFECTS OF SEAFOOD PROCESSING FACILITIES
Potential Effects on Human Communities
Of the five islands in the Pribilof archipelago, St. Paul and St. George represent the two largest land
masses (Byrd and Norvell 1993). St. Paul and St. George have approximately 750 and 150 year-round
residents, respectively (Byrd and Norvel! 1993; Sherwonit 1994). The vast majority of the residents
on these islands are Aleuts; St. Paul's residents comprise the world's largest Aleut community
(Sherwonit 1994). This community represents approximately one-fifth of the estimated 3,000
remaining Aleuts (Sherwonit 1994).
The seafood processing industry has become the primary source of revenue for Pribilof Island
communities. Historically, these communities relied almost exclusively on the fur seal industry. With
the eventual abolishment of fur seal hunting by the federal government in late 1984 (except for limited
subsistence harvests) the communities were left with no economic base upon which to rely. In 1983,
for example, approximately 95% of the City of St. Paul's income was from State and Federal
government sources (M. Lamb, City of St. Paul, pers. comm. 1995). Since then, the communities have
been gradually building an economy based on the commercial fishing and tourist industries. Since
1991, the City of St. Paul has received approximately $16.2 million in total tax revenues, with an
estimated $1 5.6 million attributable to seafood processing and related activities (e.g., crab po.t storage,
refueling of vessels, and other dock and port services) (M. Lamb, City of St. Paul, pers. comm. 1995).
Tourism, St. Paul's other primary source of revenues, currently accounts for approximately 10% of
gross revenues (Sherwonit 1994). Tourist attractions on the islands include diverse wildlife and, to a
lesser degree, cultural history. The success of tourism as an industry depends on a thriving wildlife
community.
The proposed permit is not expected to result in a large increase in development on the islands due to
the restrictions imposed on new shore-based dischargers {see Description of the Proposed Action).
Thus, the potential for construction of new facilities is fairly low. However, an increase in offshore
processing may become a burden on community resources. Increased processing would require a larger
work force which, in turn, would increase demand for resources, including fuel, utilities, food, and
water that are limited on remote islands such as the Pribilofs. In addition, an increase in vessel traffic,
an indirect affect related to additional seafood processing, heightens the probability of accidental rat
introductions and oil spills or other discharges of hazardous materials. Accidental rat introductions have
the potential for devastating effects on local island ecology, leading to reductions in species diversity
and population numbers on the islands and a corresponding decline in the tourism industry. To date,
however, no live rats have appeared in either St. Paul or St. George (Sherwonit 1994). Both cities have
extensive rat prevention programs (joint efforts between USFWS and the local communities) which
include: traps located at the harbors and inside harbor-based processing ships and shore-based plants;
and encouragement of wild foxes, which are native to the Pribilofs and are predators of Norway rats,
to frequent the harbor areas. Oil spills or other discharges of hazardous materials may also impact local
wildlife populations and the tourism industry. Potential effects may, however, be reduced with the use
of best management practices, such as spill prevention and response programs,
Potential Effects on the Aquatic Environment
Seafood processing waste discharges in general have been shown to result in adverse water quality
impacts. Typically, aquatic environments are degraded through mass loadings of BOD and
accumulations of processing wastes. The former generally leads to reduced dissolved oxygen (DO)
concentrations as the wastes decompose. Reductions in DO may negatively affect aquatic life,
particularly benthic fish and invertebrates that require specific concentrations of DO to sustain life.
However, this is most often a problem in depositiona! environments that have minimal circulation and
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mixing. As previously discussed, significant accumulations of waste physically alter habitat and may
bury or smother benthic epifauna and infauna.
Additional conventional waste pollutants are TSS and oil and grease concentrations. The TSS
components may be inorganic (e.g., crab shell or sand particulates) or organic (e.g., seafood tissue
fragments, grease, and oil). Depending on their size, these particulates may settle rapidly or remain
suspended for extended periods of time. While suspended, particulates reduce water clarity and light
penetration which may reduce the photosynthetic activity of aquatic plants including micro- and
macroaigae.. This, in turn may result in reduced DO levels within the water column, which may
adversely affect invertebrate and fish populations. Further, suspended organic material may cause
abrasive injuries to fish and shellfish or clog gills'or respiratory passages (EPA 1994b), In addition,
increased nutrients levels in receiving waters caused by waste discharges may lead to elevated growth
of plankton and algae, or the attraction of addition scavenger organisms, including certain invertebrates.
Decomposition of oil and grease components found within seafood waste reduces DO levels and may
lead to the suffocation of benthic organisms. However, as noted above, such effects are most likely
to occur in areas with minimal circulation and mixing.
Based on limited surveys to assess potential impacts from shore-based Pribilof processors it is
acknowledged that additional, comprehensive surveys and monitoring are needed to assess the
cumulative, long-term effects from seafood processing. However, existing studies suggest, that few,
if any, negative impacts to the aquatic environment can be attributable to facility operations. This is
primarily due to the limited amount of processing occurring and local oceanographic conditions (i.e.,
strong currents and wave action in the nearshore environment). Additional research will be conducted
by EPA and others during the two-year term of the proposed permit.
Potential Effects on Protected Water Resources and Special Habitats, Including Threatened and
Endangered Species
The NMFS and USFWS provided EPA with lists of species of concern, including endangered, threatened
and candidate species listed under the ESA'and depleted species listed under the MMPA, for the Pribilof
Islands area (NMFS and USFWS 1995, see Appendix A). Based on the species identified in these lists,
EPA prepared a Biological Assessment (EPA 1995c) as required by Section 7 of the ESA.
Marine mammals identified as species of concern by NMFS include the following,; bowhead (Balaena
mysticetus], northern right (Balaena glacialis], sperm (Physeter macrocephalus], blue (Ba/aenoptera
musculus), fin (Ba/aenoptera physa/us), and humpback whales (Megaptera novaeangliae); Steller sea
lions -(Eumetopias jubatus}; and northern fur seals (Callorhinus ursinus}. Rookeries and major haulouts
of the Steller sea lion, which is listed as threatened under the ESA, have been designated as critical
habitat by NMFS (Figures 1, 2, and 3). The proposed permit provides additional protection to northern
fur seal haulouts (Figures 2 and 3) during critical breeding periods by preventing seafood processing
discharges within a 0,5 nmi radius of these sites. USFWS identified three species with ESA candidate
status that are found in the Pribilof Islands: Pribilof Island shrew (Sorex hydrodromus), red-legged
kittiwake (fifssa brevirostris], and harlequin duck (Histrionicus histrionicus],
The six whales mentioned above are not likely to be adversely affected by seafood processing and
related activities in the Pribiiofs since they do not typicaiiy forage in close proximity to the islands.
Further, because seafood process discharges are not known to contain high concentrations of toxic
components, (EPA 1994a) effects are expected to be negligible.
Adverse effects from the proposed permit to sea iions and fur seals are not expected. Indirect effects
related to the seafood processing industry may occur. Potential indirect effects include disturbance
from vessel traffic, possibility of spills (e.g., fuel or oil) from fishing and processing vessels, and
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entanglement in fishing nets and other debris.
Based on evaluation of preferred habitats, it is not likely that the Pribilof Island shrew will be adversely
affected by the activities authorized by the proposed permit. This species prefers tall-grass, upland
habitats which do not generally coincide with primary seafood processing discharge areas.
The red-legged kittiwake may be indirectly affected by activities authorized under the proposed permit,
This could result from an increased potential for rat introductions, due to increases in ship traffic, and
the attraction of additional predators/scavengers (e.g., gulls) to .seafood processing wastes, thereby
leading.to increased predation of red-legged kittiwakes. The potential for impacts from rats is minimized
by the rat control program currently implemented in the Pribjiofs.
Because they do not nest in the Pribilofs, Steller's eiders and harlequin ducks are not likely to be
affected by increased predation. However, the increased vessel traffic and the associated potential for
spills may indirectly effect these species,
Potential Effects on Historical and Archaeological Sites
Review of the National Register of Historic Places indicates that there are no known submerged cultural
or archaeological resources in the vicinity of the Pribiiofs. However, there are several land-based pits,
passages, house depressions, settlements, and middens located at multiple sites on St. Paul (J.
Rukovishnikoff, City of St. Paul 1995). St. George also has at least three historical sites: a hotel,
Orthodox church, and a fur seal processing plant (A. 'Philemonof, City of St. George, pers. comm,
1995!.
Under the proposed permit, new applicants seeking to establish a shore-based processing facility must
first site it at least 3 nmi from protected Steller sea lion rookiers and 0.5 nmi from Stller sea lion habitat
(year-round) and northern fur seal habitat and critical seabird nesting areas (if they wish to process at
any time from May 1 through December 1 or May 1 through September 30, respectively), as described
in the permit. Given the small size of the Pribiiofs and relative abundance of sea lion, seal, and seabird
habitat along the coast (Figures 2 and 3), few sites will meet permit criteria and allow year-long
processing. Thus, it is unlikely that there will be many new shore-based applicants under the proposed
permit. Notwithstanding proposed permit restrictions for new applicants, any new stationary facility
will be required to obtain a Federal permit from the Corps of Engineers to construct: a dock or pier for
fishing vessels to offload their catch and an outfall to discharge process effluent. As part of permit
issuance, the facility must show compliance with Clean Water Act Section 106, ensuring that no
historical or archaeological site will be adversely affected by the proposed construction.
Potential Effects on Wetlands and Floodptains
All of the existing stationary facilities within the Pribiiofs are located on coastal lands and should be
designed to minimize flood damage from winter storm surge and tidal action. Thus, their continued
operation should pose no serious threat to coastal wetlands and floodplains. Similarly, it is in the best
interest of any new facilities proposed for construction to ensure that flood damage is avoided, mainly
by elevating the structure to heights above storm surge levels. This can be achieved by building on
top of fill or pilings. Specific permits are required for facility construction in wetlands or other waters,
as mandated by Section 404. of the Clean Water Act. These site-specific permits are designed to
minimize impacts to wetland and coastal areas, including selection of alternate construction sites that
will minimize adverse effects to wetlands or floodplains.
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Potential Effects on Agricultural Lands
Because agricultural lands are not present on the Pribilof Islands, there are no anticipated effects to
farming that could be attributed to the proposed permit.
Potential Effects on Fish and Wildlife
Significant accumulations of seafood waste can cause adverse effects to benthic invertebrate
populations through burial or smothering. Similarly, demersal fish habitat may be altered or lost if
waste piles accumulate. Should invertebrate and/or demersal fish populations become reduced,
additional effects to predatory species such as birds and pinnipeds may occur due to prey population
reductions. Because initial surveys suggest that the nearshore region surrounding the Pribilofs consists
of a high energy environment (Freese and Stone 1993; Envirotech Diving 1995), waste accumulations
are not anticipated provided processing is maintained at current levels. However, should processing
activities increase significantly during the term of the proposed permit, additional surveys may be
required to verify that processing wastes are sufficiently dispersed following discharge.
The proposed permit allows for continued seafood processing at existing stationary outfalls and
potential construction of new processing facilities, under the restricted conditions provided in the
description of the proposed action. It is currently unknown if existing seafood processing levels, or if
potential increases in processing activities adversely affect local fish and crab populations, or predator
populations such as seabirds, pinnipeds, and cetaceans. Maintenance of fishery stocks depends on a
variety of factors including fecundity, recruitment, and survivorship which are generally species
specific. Regional fishery management plans are prepared by the North Pacific Fishery Management
Council. The Council's plans are submitted to, approved, and implemented by the Secretary of
Commerce. Prior to approval, fishery management plans are reviewed under NEPA guidelines to assess
their potential environmental effects. Careful management and monitoring of fishery stocks should
conserve resources and minimize adverse effects.
Potential Effects on the Alaska Coastal Zone Management Program
The State of Alaska, Office of Management and Budget has certified that the statewide seafood
processors general NPDES permit (number AK-G52-0000) is consistent with the approved Alaska
Coastal Management Program. EPA will submit a copy of the proposed Pribilof Islands general permit
to the State Division of Government Coordination (DGC) for review by state agencies, including the
Coastal Zone Management Office, and request a consistency determination.
Potential for Irreversible and Irretrievable Commitment of Resources
Continued operation of existing Pribilof stationary and floating processors requires a commitment of
fossil fuel energy, packaging materials, a water supply, and aquatic organisms. In addition to these
resources, any new facilities will require building materials, equipment, and coastal land for the lifetime
of facility use. Given the limited number of existing facilities and reduced likelihood of new facilities
under proposed permit restrictions, the quantity of committed resources is minimal. Construction
permits required by the Corps of Engineers should further ensure that no historical resources are lost
and that important resource areas adjacent to proposed facilities are maintained.
Fishery stocks are considered renewable biological resources that are conserved through maintenance
of appropriate habitat and controlled fishery practices. The North Pacific Fisheries Management Council
provides oversight and management of local fishery stocks and has the lead in determining appropriate
habitat and for maintaining the stocks for long-term use.
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Potential Effects on Energy Resources
Due to the small number of operational processing facilities and the anticipated low number of new
facilities, substantial effects to energy supplies are not anticipated. Energy sources include diesel fuels
for electric generators and fuel for fishing vessels and facility machinery (e.g., forklifts). The proposed
permit exclusion zone of 0.5 nmi allows floating processors to discharge in closer proximity to the
Pribilofs compared to the general statewide permit exclusion zone of 1.0 nmi. The reduced discharge
range may result in less fuel usage by floating processors.
Potential Effects on Air Quality
The proposed permit will result in negligible effects to air quality; currently there are no major air
pollutant sources in proximity to the Pribilofs. Existing sources are from the limited number of facilities
and consist primarily of diesel generator and vessel engine emissions, along with processing odors.
Diesel generators emit fine particulates and nitrogen oxide (NOX) and vessels, depending on their size,
may potentially emit fine particulates, NOX, and sulfur dioxide, particularly when idling during processing
periods. The lack of major industrial sources and presence of strong prevailing winds, which serve to
rapidly disperse pollutants, ensures compliance with National Ambient Air Quality Standards and
Prevention of Significant Deterioration increments. New facilities are subject to State air permitting
requirements and must ensure that emissions do not exceed applicable air quality standards.
Potential Effects on Noise Levels
The proposed permit may directly result in increased noise levels from new processing facilities. Noise
standards for the protection of worker hearing are set locally and by the Occupational Health and Safety
Administration and should prevent any significant noise impacts near facility sites. In addition, the
proposed permit may indirectly effect noise levels through increases in vessel traffic, which may
potentially disrupt some feeding or breeding activities of resident seabird, waterfowl, or pinniped
populations, or cetacean migratory patterns (Richardson et al. 1991). However, because the proposed
permit restricts processing and discharge activities during the summer breeding season, and known
whale migratory routes are not in close proximity to the Pribilofs, adverse effects are not anticipated
other than temporary, localized disruptions of seabird and pinniped foraging.
Potential Cumulative and Long-term Impacts to the Aquatic Environment and Biological Resources
Cumulative impacts are defined as the synergistic effect of a variety of sources impacting both water
quality and biological resources residing in or migrating through regional waters. Impact sources
directly related to the proposed permit include the seafood discharges from each of the five shore-based
outfalls, any potential new shore-based facilities, and all mobile processors operating in the Pribilofs;
and sanitary discharges' from moored vessels and shore-based facilities. Impact sources indirectly
related to the proposed permit include oil or fuel leaks from fishing and/or processing vessels. The use
of current waste treatment technologies and the conditions of the proposed permit, including sea
surface and shoreline monitoring requirements will reduce the potential for adverse cumulative effects.
Future research and monitoring activities conducted by EPA and others during the term of the proposed
permit will provide additional information related to potential cumulative effects.
Seafood processing wastes do not contain significant quantities of toxic pollutants that may
bioaccumulate in aquatic organisms, and therefore do not pose a long-term threat to the health of
aquatic organisms or humans. Solids wastes have not been observed to accumulate and persist in the
vicinity of seafood processing waste discharges in the Pritai.Iof Islands, Disinfectants used during food
processing are potentially toxic constituents that will be discharged, from the seafood processing
facilities. However, it is expected that the.concentration of disinfectants will be reduced due to dilution
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with other wastewaters prior to discharge and that these constituents will not be present at toxic
concentrations following discharge,
Potential Effects on Short-term Use vs. Long-term Productivity
Proposed permit restrictions, including sea surface and shoreline monitoring requirements and the
maintenance of existing Notice of Intent (NOI) processing levels, should prevent any significant adverse
impacts to the aquatic environment and biological resources. Proper fishery management also should
result in a continuing supply of seafood for existing and potential new processors. In addition,
proposed or existing processors are not known to cause any long-term risks to human health and
safety, but rather are a viable means of economic support in a remote environment. Thus, the proposed
permit is not expected to adversely affect long-term productivity.
ALTERNATIVES CONSIDERED
The following describes other alternatives to issuance of the proposed permit, including the no-action-
alternative. An analysis of potential'environmental and socioeconomic effects for each alternative is
also provided.
No-Action Alternative
The no-action alternative would result in continued coverage of exisiting permitted seafood processors
within 3 nmi of the Pribilofs under the 1989 Alaskan Seafood Processors General NPDES Permit.
However, because the 1989 permit has expired and new applicants are not eligible for coverage under
an expired permit, the no-action alternative would not authorize discharges from new processors. In
addition, processing activities of existing facilities covered under the 1989 permit would be limited to
levels indicated in their NOI. In effect, the no-action alternative would limit seafood processing in the
Pribilofs region to current levels. In addition, the 1989 permit was finalized before NMFS designated
critical habitat for the Steller sea iion. Consequently, this permit does not afford appropriate protection
to this critical habitat.
The no-action alternative, if chosen, would likely have a negative impact on the economies of St. Paul
and St. George. Limiting seafood processing to current levels could cause economic hardship as the
seafood industry provides the majority of local community income. In addition, continuation of
operations under the 1989 permit, which does not afford adequate protection to listed and proposed
threatened and endangered species, may result in adverse effects to protected species. On the other
hand, limiting processing to current levels may reduce the potential for adverse cumulative or long-term
effects.
Coverage of Pribllof Processors Under 1995 Alaskan Seafood Processors General NPDES Permit
Under this alternative, Pribilof shore-based and mobile processors would be restricted from discharging
within 1 nmi of northern fur seal or walrus rookeries from May 1 through November 15; within 1 nmi
of nesting seabird colonies containing 5,000 or more individuals from May 1 through September 30;
and within 3 nmi of Steller sea iion critical habitat. Due to the close proximity of existing shore-based
processors to rookery and nesting areas (Figures 2 and 3), these facilities would be unable to operate
during the critical periods mandated by the permit. Although the majority of processing occurs from
November through March, some processing occurs throughout spring and summer months {Figure 4),
Restriction from processing for five months or more may represent substantial economic hardship for
existing facilities.
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issuance of Separate NPDES Permits for Individual Seafood Processing Facilities
in the absence of a general permit, each processor would be required to submit individual NPDES permit
applications to EPA. EPA would then be required to review, write, publicize, and issue each of these
individual permits. This process would undoubtedly consume significant time and resources, and may
potentially lead to a lengthy period for processors awaiting authorization to discharge. This alternative
is undesirable from several perspectives. First, it would require EPA to expend more resources on
permit authorization and less on research and other activities." Second, it may impose economic
hardships on those facilities awaiting permit authorization due to the costs associated with preparing
individual permit applications and loss of processing revenues while awaiting permit issuance.
Modifications to the Terms of the Proposed Pribilofs General Permit
The following suggested modification to the proposed permit may serve to diminish potential
environmental effects without causing substantial economic hardship. In order to limit potential adverse
effects from processing activities during critical breeding and nesting periods (i.e.. May through
November), seafood processing wastes generated at existing shore-based facilities that are in excess
of production levels indicated in the facilities existing NOI, could be barged to a designated offshore
disposal site. This would allow processors to operate during, critical periods while limiting the extent
of effects to protected resources (i.e., Steller sea lions, northern fur seals, and nesting seabird
colonies). In addition, in order to reduce the potential for accidental spills and rat introductions, all
seafood processing related vessels, including floating processors, catch vessels, and refueling vessels,
traveling within a 3 nrni radius of the Pribiiofs must be piloted by a licensed pilot.
MITIGATION
Due to the limited amount of baseline environmental information available for the Pribilofs related to
seafood processing discharge and potential environmental effects, it is not yet appropriate to identify
mitigation measures. During the two-year term of the proposed permit, appropriate studies, surveys,
and monitoring will be conducted to identify any potential adverse effects from process discharges,
including cumulative and long-term- effects. The resulting data and information will be used in
developing the subsequent permit and will provide mitigation measures, should they be deemed
necessary.
PUBLIC PARTICIPATION
in accordance with NEPA regulations, this environmental assessment, along with the draft proposed
permit and fact sheet will be made available for public review and comment. The comment period will
extend for thirty days from the date of notice in the Federal Register. Public hearings will be convened
to discuss issues related to the proposed permit only if requested. All written comments submitted by
the public to EPA will be fully considered and responded to before final action is taken.
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REFERENCES
Byrd, V.G, and N. Norvell. 1993. Status of the Pribilof Shrew Based on Summer Distribution and
Habitat Use. Northwestern Naturalist:49-74,
Envirotech Diving. 1995. Dive Survey, St. Paul Island, AK. Prepared for UniSea, Inc.
Freese, L. J. and R.P. Stone. 1993. Baseline Environmental Survey of Nearshore Habitat at East
Landing, St. Paul Island, Pribilof Islands, Alaska. Alaska Fisheries and Science Center Auke Bay
Laboratory, Juneau, Alaska.
Lamb, M. City of St. Paul. St. Paul, Alaska. Telephone conversation with Jim Siriano (SAICS, July
1995.
Philemonof, A, City of St. George. St. George, Alaska. Telephone conversation with Jim Siriano
(SAIC), July 1995.
Richardson W.J., Greene, Jr., C.R., Malme, C.I., and D.H. Thomson. 1991. Effects of Noise on
Marine Mammals. Prepared by LGL Ecological Research, Inc. for the U.S. Department of the
Interior, Minerals Management Service, Herndon, VA. 419 pp. with Appendices and Index.
Rukovishnikoff, J. City of St. Paul. St. Paul, Alaska. Telephone conversation with Jim Siriano (SAIC),
July 1995.
Sherwonit, B. 1994. Taking Back the Pribilofs. Alaska, September 1994, pp. 24-31.
U.S. EPA, 1994a, Biological Assessment of Seafood Processing Wastes on Threatened and
Endangered Species in Alaskan Waters. Draft Report prepared by Tetra Tech. 25 pp.
U.S. EPA. 1994fa. Environmental Assessment: Proposed Reis'suance of NPDES Permit for Seafood
Processors in Alaska. 25 pp.
U.S. EPA., 1994c. Ocean Discharge Criteria Evaluation for the General NPDES Permit for Alaskan
Seafood Processors: Draft Technical Report. Prepared by Tetra Tech.
U.S. EPA. 1995a. Draft Pribilof Seafood General Permit No. AK-G52-POOO. Authorizations to
Discharge Under the National Pollutant Discharge Elimination System for Seafood Processors
Within Three Nautical Miles of the Pribilof Islands. 26 pp.
U.S. EPA. 1995b. NPDES Permit No. AK-G52-0000. Authorization to Discharge Under the National
Pollutant Discharge Elimination System for Seafood Processors in Alaska. 57 pp.
U.S. EPA. 1995c. Biological Assessment of Seafood Processing Discharges on Threatened,
Endangered, and Special Status Species of the Pribilof Islands, Alaska. Prepared by Science
Applications International Corporation.
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