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2004
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Canned
and
Preserved
Seafood
Processing
(
40
CFR
408)
Detailed
Investigation
for
2004/
2005
Planning
Process
Executive
Summary
During
the
Screening
Level
Review
phase
of
the
2004/
2005
planning
process,
canned
and
preserved
seafood
processing
was
one
of
eight
industrial
categories
identified
solely
through
Factor
4
concerns.
Issues
driving
the
concerns
include
1)
discharges
of
nutrients
and
conventional
pollutants
resulting
in
overloading
of
POTWs
and
small
streams,
2)
no
limits
for
pollutants
such
as
nutrients
and
pathogens,
now
causing
concern,
and
3)
changes
control
technologies
since
the
promulgation
of
the
guidelines.
Based
on
information
reported
to
the
Toxic
Release
Inventory
(
TRI)
and
the
Permit
Compliance
System
(
PCS),
EPA
has
concluded
that
toxic
discharges
from
seafood
processing
plants
are
low
relative
to
other
industrial
categories.
Sulfide
from
a
single
facility
contributes
almost
99%
of
the
overall
toxic
weighted
pound
equivalents
(
TWPE)
discharged
by
this
industry.
However,
most
of
these
pollutants
do
not
have
toxic
weighting
factors,
so
discharges
of
these
substances
cannot
be
assessed
in
terms
of
potential
risk.

The
information
in
the
record
at
this
time
does
not
support
a
decision
to
revise
these
effluent
guidelines.
In
the
event
that
stakeholders
provide
additional
data
and
supporting
information
during
subsequent
review
cycles,
EPA
will
reevaluate
them
at
that
time.
In
the
absence
of
revisions
to
the
effluent
guidelines,
these
concerns
could
be
addressed
through
improved
information
dissemination
and
outreach
by
EPA.
The
Agency
could
prepare
a
fact
sheet
with
answers
to
frequently
asked
questions
(
FAQs),
including
the
names
of
current
contacts
within
EPA's
Office
of
Water.
The
Agency
could
announce
the
availability
of
this
fact
sheet
at
the
regular
meetings
for
permit
writers
and
pretreatment
coordinators
held
by
the
Office
of
Wastewater
Management
(
OWM)
and
through
internet
postings
and
email
alerts
to
the
Engineering
and
Analysis
Division
(
EAD)
stakeholders
mailing
list.
Finally,
due
to
the
presence
of
a
single
facility
discharging
the
bulk
of
the
TWPE,
EPA
could
also
provide
assistance
to
permit
writers
in
preparing
BPJ­
based
permits.

Overview
This
report
presents
information
for
the
following
topics:
Background
Industry
and
Related
Subcategories
Wastewater
Characteristics
and
Pollutant
Sources
Pollutants
Discharged
Treatment
Technology
and
Pollution
Prevention
Concerns
Identified
Pre­
Proposal
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Concerns
Identified
in
Comments
to
Proposal
Additional
Concerns
Identified
Post­
Proposal
Followup
Contacts
Possible
Solutions
Attachments
provide
the
following
supporting
information:
EPA
Databases
and
References
Used
in
this
Review
Point
Source
Categories
Identified
Solely
Through
Factor
4
Guidelines
Applicability
and
Regulatory
History
PCS
Discharges
TRI
Discharges
Reported
Pollutant
Loadings
Background
In
preparation
for
proposing
the
Preliminary
Effluent
Guidelines
Program
Plan
for
2004/
2005
("
Preliminary
Plan,"
published
in
February
2004),
EPA
analyzed
four
factors
identified
in
the
draft
"
National
Strategy
for
Industrial
Clean
Water"(
Edocket
OW­
2003­
0074­
0215).
See
Attachment
A
for
more
background
about
the
304(
m)
planning
Process.
The
four
factors
focus
on:
1
Potential
impacts
to
human
health
and
the
environment.
Preliminary
results
are
summarized
in
the
"
Factor
1
Analysis:
Human
Health
and
Environmental
Impacts
 
Status
of
Screening
Level
Review
Phase"
(
Edocket
OW­
2003­
0074­
0410).
2
Identification
of
an
applicable
and
demonstrated
technology,
process
change,
or
pollution
prevention
alternative
that
can
effectively
reduce
pollutants
discharged.
Preliminary
results
are
summarized
in
the
"
Factor
2
Analysis:
Technology
Advances
and
Process
Changes
 
Status
of
Screening
Level
Review
Phase."
(
Edocket
OW­
2003­
0074­
0287).
3
Evaluation
of
the
cost,
performance,
and
affordability
of
the
technology,
process
change,
or
pollution
prevention
measures
identified
using
the
second
factor.
4
Implementation
and
efficiency
concerns.
Preliminary
results
are
presented
in
the
"
Factor
4
Analysis:
Implementation
and
Efficiency
Considerations
 
Status
of
Screening
Level
Review
Phase"
(
Edocket
OW­
2003­
0074­
0329)

When
all
of
the
results
were
integrated
prior
to
proposing
the
Preliminary
Plan,
EPA
determined
that
8
point
source
categories
with
existing
effluent
guidelines
had
been
identified
solely
through
Factor
4
concerns.
(
See
list
in
the
Attachment
B.)
In
order
to
determine
the
best
course
of
action
to
address
these
concerns,
EPA
performed
an
analysis
of
issues
and
potential
solutions
for
each
of
the
8
categories.
The
results
of
that
analysis
for
Canned
and
Preserved
Seafood
Processing
are
presented
in
this
report.
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Industry
and
Related
Subcategories
The
Canned
and
Preserved
Seafood
Processing
point
source
category
is
regulated
at
40
CFR
408.
See
Attachment
C
for
the
applicability
and
regulatory
background.
This
point
source
category
includes
facilities
reporting
under
Standard
Industrial
Classification
(
SIC)
industry
group
20,
Food
and
Kindred
Products.
Specifically,
it
includes
SIC
2091,
Canned
and
Cured
Fish
and
Seafoods,
and
SIC
2092,
Prepared
Fresh
or
Frozen
Fish
and
Seafoods.
No
specific
subcategories
were
identified
during
the
Factor
4
analysis;
however,
followup
discussions
identified
about
150
companies,
primarily
in
Washington
and
Alaska
that
are
categorized
under
SIC
2091,
and
just
under
600
companies
categorized
under
SIC
2092.

°
SIC
2091
­
Canned
and
Cured
Fish
and
Seafoods
Establishments
primarily
engaged
in
cooking
and
canning
fish,
shrimp,
oysters,
clams,
crabs,
and
other
seafoods,
including
soups;
and
those
engaged
in
smoking,
salting,
drying,
or
otherwise
curing
fish
and
other
seafoods
for
the
trade.

°
SIC
2092
­
Prepared
Fresh
or
Frozen
Fish
and
Seafoods
Establishments
primarily
engaged
in
preparing
fresh
and
raw
or
cooked
frozen
fish
and
other
seafoods
and
seafood
preparations,
such
as
soups,
stews,
chowders,
fishcakes,
crab
cakes,
and
shrimp
cakes.
Prepared
fresh
fish
are
eviscerated
or
processed
by
removal
of
heads,
fins,
or
scales.
This
industry
also
includes
establishments
primarily
engaged
in
the
shucking
and
packing
of
fresh
oysters
in
nonsealed
containers.

The
following
tables
present
the
facilities
in
this
category
that
report
to
the
Permit
Compliance
System
(
PCS)
and
to
the
Toxic
Release
Inventory
(
TRI).
(
Note:
Since
this
industry
ranked
low
during
the
screening
phase,
EPA
did
not
verify
any
of
the
information
reported
to
PCS
and
TRI,
and
has
used
it
as
reported.
Although
information
in
PCS
and
TRI
is
limited,
it
can
provide
insight
into
this
industry.
See
Attachment
A
for
more
details
about
PCS
and
TRI.)
Table
1
shows
the
number
of
facilities
identified
for
this
industry.
Table
2
lists
the
facilities
reporting
to
PCS
under
these
SIC
codes.
Table
3
lists
the
facilities
reporting
to
TRI
under
these
SIC
codes.
Attachments
D
and
E
list
these
facilities
along
with
their
reported
discharges.
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Table
1.
Number
of
Facilities
SIC
1997
Census
PCS
TRI
Total
Major
Minor
Total
Reporting
No
reported
discharge
Direct
discharge
Indirect
discharge
Both
direct
&
indirect
2091
163
19
5
14
5
5
0
0
0
2092
669
70
3
67
5
3
2
0
0
Source:
PCSLoads2000,
TRIReleases2000
Table
2.
Canned
and
Preserved
Seafood
Processing
Facilities
Reporting
to
PCS,
Sorted
by
State
SIC
NPDES
ID
NAME
CITY
STATE
2091
AK0028657
UNISEA
INC
(
also
reports
to
TRI)
DUTCH
HARBOR
AK
2091
AK0000272
ALYESKA
SEAFOODS
INC
UNALASKA
AK
2092
AK0037303
TRIDENT
SEAFOODS
CORP
AKUTAN
AK
2091
OH0003298
CAMPBELL
SOUP
COMPANY
NAPOLEON
OH
2092
RI0001121
BLOUNT
SEAFOOD
CORPORATION
WARREN
RI
2091
PR0023043
MAYAGUEZ
WATER
TREATMENT
CO
MAYAGUEZ
PR
Table
3.
Canned
and
Preserved
Seafood
Processing
Facilities
Reporting
to
TRI
SIC
Facility
TRI
ID
Facility
Name
City
State
2092
99692NSNC
POUCH
UNISEA
INC.
DUTCH
HARBOR
AK
2092
38751DLTPRINDIA
DELTA
PRIDE
CATFISH
INC.
INDIANOLA
MS
Of
the
7
facilities
reporting
discharges
to
PCS
or
TRI,
3
are
located
in
Alaska.
The
others
are
located
in
Mississippi,
Ohio,
Rhode
Island,
and
Puerto
Rico.
The
map
on
the
following
page
shows
the
locations
of
the
facilities
reporting
to
TRI
or
PCS.

1997
U.
S.
Census
data
provides
data
that
illustrates
the
changes
in
the
number
of
the
number
of
facilities
and
in
the
value
of
goods
shipped
between
1992
and
1997.
See
Table
4
below.
Advance
comparative
statistics
for
1997
to
2002
for
NAICS
code
311
(
food
manufacturing
including
grains,
fruits
and
vegetables,
dairy,
meats,
seafood,
and
miscellaneous
food)
a
very
small
increase
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in
the
number
of
establishments
(
less
than
1%)
and
an
8%
increase
in
the
value
of
shipments
(
not
adjusted
for
inflation).
See
Table
5
below.

Table
4.
1992
and
1997
Census
Data
SIC
Industry
Sector
Number
of
Establishments
Value
of
Goods
Shipped
(
millions
of
dollars)

1997
1992
%
Change
1997
1992
%
Change
2091
Canned
and
Cured
Fish
and
Seafoods
163
159
2.5
854
969
­
11.9
2092
Prepared
Fresh
or
Frozen
Fish
and
Seafoods
669
685
­
2.3
7,039
W
NA
Source:
1997
U.
S.
Economic
Census.
W
indicates
that
data
were
withheld
to
avoid
disclosure.
NA
indicates
that
comparable
data
were
not
available.

Table
5.
1997
and
2002
Census
Data
NAICS
Industry
Segment
Number
of
Establishments
Value
of
Goods
Shipped
(
billions
of
dollars)

2002
1997
%
Change
2002
1997
%
Change
311
Food
Manufacturing
26,374
26,302
0.27
457
422
8.4
Source:
2002
U.
S.
Economic
Census
Wastewater
Characteristics
and
Pollutant
Sources
Table
6
presents
information
about
wastewater
flows
for
this
industry.
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Table
6.
Wastewater
Flows
SIC
code
Number
of
Major
Facilities
Reporting
Nonzero
Flows
Median
Facility
Flow
2000
(
MG)
Range
of
Facility
Flows
2000
(
MG)
Total
Flow
2000
(
MG)

2091
4
736
523
­
1679
3,674
2092
2
518
31
­
1006
1,036
Source:
PCSLoads2000.

Wastewater
is
high
in
solids,
dissolved
proteins,
BOD,
oil
and
grease,
organic
nitrogen,
and
ammonia.
Wastewater
sources
in
seafood
processing
include
thawing,
butchering,
washing,
peeling,
picking,
meat
flumes,
separators,
cooking,
and
cleaning.
Wastes
generally
include
carcasses,
shells,
trimmings,
and
by­
catch
not
suitable
for
human
consumption.

Pollutants
Discharged
Pollutant
discharges
to
surface
waters
as
reported
to
PCS
and
TRI
were
evaluated
as
part
of
the
Factor
1
Analysis:
Human
Health
and
Environmental
Impacts.
Pounds
reported
as
discharged
were
converted,
wherever
possible,
to
their
toxic
weighted
pound
equivalents
to
provide
a
sense
of
relative
hazard
associated
with
those
discharges.
(
Note:
indirect
discharge
amounts
reflect
reductions
that
are
expected
to
occur
at
the
receiving
treatment
facility.)
Both
TRI
and
PCS
contain
information
about
pollutants
discharged
by
seafood
processing
facilities.

Discharges
reported
to
PCS
by
a
single
facility
in
Puerto
Rico
account
for
almost
100%
of
the
toxic
weighted
pound
equivalent
(
TWPE)
discharges
for
this
industry.
These
TWPE
are
due
to
the
discharge
of
sulfides.
Discharged
pollutants
can
be
characterized
as
nonconventional,
conventional,
or
priority
pollutants.

PCS:
Of
the
6
facilities
reporting
to
PCS,
one
facility
in
Alaska
accounts
for
83%
of
the
pounds
reported
as
discharged.
A
second
facility
also
in
Alaska
contributes
an
additional
13%
of
the
pounds
discharged.
When
looking
at
toxic
weighted
discharges,
a
single
facility
in
Puerto
Rico
accounts
for
over
99%
of
the
TWPE
discharged.

TRI:
Of
the
2
facilities
reporting
to
TRI,
a
facility
in
Mississippi
contributes
84%
of
the
total
pounds
reported
as
discharged.
When
looking
at
toxic
weighted
discharges,
the
second
facility,
located
in
Alaska,
accounts
for
over
65%
of
the
TWPE
discharged.

Overall:
Of
the
7
facilities
(
one
reports
to
both
databases),
one
facility
in
Alaska
accounts
for
82%
of
the
total
pounds
reported
as
discharged.
A
second
facility
also
in
Alaska
contributes
an
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additional
13%
of
the
pounds
discharged.
When
looking
at
toxic
weighted
discharges,
a
single
facility
in
Puerto
Rico
accounts
for
over
99%
of
the
total
TWPE
discharged.

Table
7
below
shows
the
relative
contributions
of
each
pollutant
type.
See
Attachment
D
for
the
discharges
in
toxic
weighted
pounds
as
reported
to
PCS
by
each
facility
and
see
Attachment
E
for
the
discharges
in
toxic
weighted
pounds
as
reported
to
TRI
by
each
facility
See
Attachment
F
for
a
breakout
of
these
discharges
by
pollutant.
A
discussion
of
each
pollutant
type
discharged
follows
the
table.

Table
7.
Pollutant
Discharges
Reported
to
PCS
and
TRI
Pollutant
Category
&
Primary
Pollutants*
PCS
LBS
PCS
TWPE
TRI
POUNDS
TRI
TWPE
All
Pollutants
103,177,359
18,961
53,562
20
Nonconventional
969,315
18,933
53,562
20
TOTAL
SULFIDE
6,728
18,842
(
100%)
0
0
AMMONIA
AS
NITROGEN
4,988
9
11,388
17
(
87%)

NITROGEN,
NITRATE
TOTAL
431,852
27
42,174
3
(
13%)

Conventional
102,207,906
0
0
0
BIOCHEMICAL
OXYGEN
DEMAND
48,117,494
 
 
 
TOTAL
SUSPENDED
SOLIDS
38,672,465
 
 
 
OIL
AND
GREASE
15,417,947
 
 
 
Priority
138
28
0
0
LEAD
7
17
0
0
COPPER
9
6
0
0
ZINC
122
6
0
0
Nonconventional
Pollutants
Although
only
1%
of
the
pounds
of
both
discharged
pollutants
reported
to
TRI
and
PCS
are
nonconventional
pollutants,
these
pollutants
account
for
almost
100%
of
all
TWPE.
Sulfide
contributes
almost
100%
of
the
nonconventional
TWPE
discharged
in
PCS
and
99%
of
the
overall
TWPE
discharged.
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Conventional
Pollutants
About
99%
of
the
total
discharged
pounds
reported
to
PCS
are
conventional
pollutants.
These
discharges
are
comprised
of
biochemical
oxygen
demand,
(
47%),
total
suspended
solids
(
38%),
and
oil
and
grease
(
15%).
However,
toxic
weights
are
not
available
for
conventional
pollutant
parameters.
No
information
on
conventional
pollutants
is
available
through
TRI.

Priority
Pollutants
Only
a
very
small
amount
of
the
total
discharged
pounds
or
TWPE
reported
to
PCS
or
TRI
are
priority
pollutants.
Only
three
priority
pollutants
are
reported
as
discharged:
lead,
copper,
and
zinc.

For
purposes
of
comparison,
the
toxic
weighted
pound
equivalents
(
TWPE)
for
Canned
and
Preserved
Seafood
Processing
are
presented
in
the
following
tables
along
with
the
industries
reporting
the
highest
discharges
in
each
database.
Table
8
presents
the
information
reported
to
PCS
and
Table
9
presents
the
information
reported
to
TRI.
For
a
description
of
the
derivation
of
the
values
in
these
tables,
see
the
memo
in
the
public
record
titled
"
Description
and
Results
of
EPA
Methodology
to
Synthesize
Screening
Level
Results
for
the
Effluent
Guidelines
Program
Plan
for
2004/
2005,"
which
is
available
through
Edocket
at
document
number
OW­
2003­
0074­
0391.

Table
8.
Canned
and
Preserved
Seafood
Processing
TWPE
Reported
to
PCS
Compared
to
Top
Ranking
Results
40
CFR
Part
Point
Source
Category
PCS
Reported
TWPE
PCS
Rank
423
Steam
electric
power
generation
2,933,209
1
414
Organic
chemicals,
plastics
and
synthetic
fibers
1,805,928
2
422
Phosphate
manufacturing
1,095,321
3
415
Inorganic
chemicals
manufacturing
853,568
4
421
Nonferrous
metals
manufacturing
434,925
5
440
Ore
mining
and
dressing
383,560
6
410
Textile
mills
296,601
7
419
Petroleum
refining
198,251
8
455
Pesticide
chemicals
manufacturing,
formulating
178,977
9
418
Fertilizer
manufacturing
116,464
10
408
Canned
and
Preserved
Seafood
Processing
18,961
20
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29
Table
9.
Canned
and
Preserved
Seafood
Processing
TWPE
Reported
to
TRI
Compared
to
Top
Ranking
Results
40
CFR
Part
Point
Source
Category
TRI
Reported
TWPE
TRI
Rank
414
Organic
chemicals,
plastics
and
synthetic
fibers
7,303,782
1
423
Steam
electric
power
generation
1,856,645
2
421
Nonferrous
metals
manufacturing
978,450
3
430
Pulp,
paper
and
paperboard
(
Phase
II)
628,785
4
415
Inorganic
chemicals
manufacturing
624,250
5
429
Timber
products
processing
404,926
6
419
Petroleum
refining
385,347
7
455
Pesticide
chemicals
manufacturing,
formulating
324,393
8
428
Rubber
manufacturing
166,343
9
463
Plastic
molding
and
forming
106,189
10
408
Canned
and
Preserved
Seafood
Processing
20
42
Treatment
Technology
and
Pollution
Prevention
Most
processing
plants
use
screening
and
sedimentation
for
solids­
liquid
separation,
dissolved
air
flotation
units,
and
biological
treatment.
Seafood
processing
plants
also
employ
in­
process
controls
such
as
water
management
and
by­
product/
waste
recovery.

Pollution
prevention
efforts
focus
on
reductions
in
BOD
and
wastewater
management,
such
as
byproduct
recovery,
in­
plant
controls,
and
recycling.
Increased
contact
between
water
and
seafood
products
and
wastes
is
undesirable
because
it
results
in
higher
pollutant
loadings
and
decreases
the
nutritional
value
of
by­
products.
Table
10
presents
water
conservation
and
pollution
prevention
alternatives
for
this
industry.
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Table
10.
Water
Conservation
and
Pollution
Prevention
Alternatives
Process
Water
Conservation/
Pollution
Prevention
Alternative
Cleaning
°
Reuse
water
from
"
clean"
processes
in
less
hygiene­
demanding
processes,
such
as
cleaning.
°
Filter,
store,
and
reuse
cleaning
water.

Recycling
°
Install
heat
pump
evaporator
to
reduce
BOD
concentrations
in
wastewater
to
allow
for
a
closed­
loop
process.
Eliminates
water
discharge.
a
Transportation
°
Use
dry
handling
in
place
of
flumes
for
in­
plant
transport
of
products.
°
Use
collection
hoppers
to
collect
dry
waste
from
butchering
and
clean
up
to
eliminate
waste
flumes.
°
Collect
dry
wastes
using
pneumatic
brooms
or
nozzles
in
place
of
water.

By­
product
recovery
°
Recover
protein
from
wastewater
for
use
as
fish
meal
or
animal
feed.
°
Early
recovery
of
solids
from
wastewater
lowers
BOD
and
nitrogen,
and
avoids
decomposition
of
potentially
valuable
byproducts.

Sources:
Technical
Development
Documents
1974
and
1975,
Anderson,
Driscoll,
Carawan,
and
Pacific
Northwest
Pollution
Prevention
Research
Center
aThe
heat
pump
evaporator
was
used
in
a
case
where
a
local
publicly
owned
treatment
works
(
POTW)
did
not
have
enough
capacity
to
treat
a
crabmeat
processor's
wastewater,
which
was
high
in
biochemical
oxygen
demand.

Concerns
Identified
Pre­
Proposal
Canned
and
Preserved
Seafood
Processing
was
identified
by
several
groups
surveyed
by
the
Agency
in
the
process
of
preparing
the
2004/
2005
Plan.
Each
group
and
their
suggestions
are
summarized
below.

Previous
Suggestions
(
Sec.
2.4
of
the
"
Factor
4
Analysis:
Implementation
and
Efficiency
Considerations
 
Status
of
Screening
Level
Review
Phase"
(
Edocket
OW­
2003­
0074­
0329)
In
the
fall
of
1999
and
again
in
the
spring
of
2001,
the
Engineering
and
Analysis
Division
(
EAD)
requested
suggestions
from
headquarters,
regional,
and
state
staff
charged
with
the
task
of
implementing
effluent
guidelines
to
follow
up
on
concerns
and
to
gather
recommendations
regarding
which
effluent
guidelines
the
Agency
might
develop
or
revise.
Responders
identified
Canned
and
Preserved
Seafood
Processing
on
the
basis
of
concerns
over
the
discharge
of
nutrients.
They
were
also
concerned
about
overloading
publicly
owned
treatment
works
(
POTWs)
and
small
streams
(
for
direct
dischargers)
with
conventional
pollutants
such
as
biochemical
oxygen
demand
(
BOD).
FINAL
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2004
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29
Draft
Strategy
Outreach:
Permitting
Authorities
(
Sec.
2.5
of
the
"
Factor
4
Analysis")
Upon
announcing
the
draft
Strategy
in
2002,
EPA
began
collecting
information
from
experts
in
effluent
guidelines
implementation.
This
includes
management
and
staff
in
the
Office
of
Wastewater
Management
(
OWM)
in
headquarters.
It
also
includes
EPA
regional
and
State
permit
writers
for
the
National
Pollutant
Discharge
Elimination
System
(
NPDES),
pretreatment
coordinators,
and
coordinators
for
the
Total
Maximum
Daily
Load
(
TMDL)
program.
These
EPA
permit
writers
and
pretreatment
coordinators
identified
concerns
for
Canned
and
Preserved
Seafood
Processing
guidelines.
Issues
include
the
discharge
of
conventional
pollutants
biochemical
oxygen
demand
(
BOD)
and
pathogens,
especially
fecal
coliform
during
seafood
processing.

State
permitting
authorities
(
Washington)
also
noted
that
the
guidelines
are
out
of
date
(
originally
promulgated
in
1974)
and
need
to
be
updated.
Alaska
noted
that
6
of
its
7
impairments
are
due
to
seafood
processing,
specifically
from
discharges
of
residues
and
resulting
dissolved
gas
concentrations.

Draft
Strategy
Outreach:
AMSA
&
ASIWPCA
(
Sec.
2.6
of
the
"
Factor
4
Analysis")
Upon
announcing
the
draft
Strategy
in
2002,
EPA
gathered
information
from
stakeholders
in
two
water
pollution
control
associations:
Association
of
Metropolitan
Sewerage
Agencies
(
AMSA)
and
the
Association
of
State
and
Interstate
Water
Pollution
Control
Authorities
(
ASIWPCA).
In
a
teleconference
with
ASIWPCA
members,
EAD
listed
the
discharge
categories
with
existing
effluent
guidelines
identified
by
other
stakeholders
as
possibly
warranting
revision.
In
response,
ASIWPCA
stakeholders
made
several
points.
First,
Canned
and
Preserved
Seafood
Processing
effluent
guidelines
do
not
regulate
pollutants
now
understood
to
cause
problems,
and
in
general,
discharge
nutrients
and
fecal
coliform
for
which
there
are
no
limits.
Second,
these
guidelines
are
out
of
date,
requiring
only
screening
of
the
effluent,
when
the
available
technology
has
advanced
well
beyond
this
level.

Concerns
Identified
in
Comments
to
Proposal
No
concerns
for
the
Canned
and
Preserved
Seafood
Processing
point
source
category
were
received
in
comments
sent
in
response
to
the
Preliminary
Plan.

Additional
Concerns
Identified
Post­
Proposal
One
stakeholder
noted
that
POTWs
would
also
benefit
from
more
EPA
assistance
in
managing
high
strength
wastewater
(
total
suspended
solids
(
TSS),
BOD
and
ammonia).
EPA
lists
these
among
the
15
Pollutants
of
Concern
(
POCs)
in
the
new
Local
Limits
Guidance
Manual,
however
conventional
pollutant
management
it
is
not
integrated
into
many
aspects
of
this
manual.
In
addition,
the
pretreatment
community
should
be
reminded
of
the
relationship
between
accepting
high
strength
BOD
wastewater,
and
meeting
ammonia
limits.
Finally,
Alaska
seafood
processors
FINAL
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2004
Page
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29
have
not
yet
converted
to
recovering
by­
products
for
other
uses,
which
could
significantly
reduce
pollutant
loadings.

Followup
Contacts
Don
Anderson,
EPA/
OST/
EAD
(
202)
566­
1021
Glenda
Dean,
Alabama
DEM,
(
334)
270­
5602
Katy
McKerney,
Alaska
Department
of
Environmental
Quality,
(
907)
465­
5302
Dave
J.
Knight,
Washington
State
DEQ,
(
360)
407­
6277
Possible
Solutions
EPA
appreciates
all
comments
and
suggestions
provided
by
the
stakeholders
and
EPA
Regional
staff.
Some
stakeholders
identified
nutrient
discharges
from
seafood
processing
plants
as
a
concern.
Information
in
PCS
and
TRI
does
not
indicate
that
seafood
processing
plants
are
discharging
significant
quantities
of
nutrients
relative
to
other
industrial
categories.
As
with
any
comments
received
by
the
Agency,
EPA
can
not
address
these
suggestions
without
adequate
supporting
data.
In
the
event
that
stakeholders
provide
additional
data
and
supporting
information,
on
these
or
any
of
the
issues
identified
above,
EPA
will
reevaluate
them
at
that
time.
State
permitting
authorities
also
suggested
that
EPA
should
revise
the
existing
guidelines
to
include
limitations
for
fecal
coliform.
EPA
does
not
generally
regulate
fecal
coliform
in
effluent
guidelines.
In
the
absence
of
revisions
to
the
effluent
guidelines,
these
concerns
could
be
addressed
through
improved
information
dissemination
and
outreach
by
EPA.

Overloading
by
nutrients
and
conventional
pollutants:
EPA
could
provide
more
assistance
in
managing
high
strength
wastewater
(
BOD,
TSS,
Ammonia).
One
way
would
be
to
integrate
management
of
conventional
pollutants
into
its
new
Local
Limits
Guidance
Manual.
An
update
of
the
1971
document
"
Equitable
Recovery
of
Industrial
Waste
Treatment
Costs"
could
be
helpful
POTW's
needing
to
manage
their
capacity
and
recover
the
costs
for
high
strength
users
(&
users
with
high
peaking
factors
for
flows
or
loadings).
Water
Environment
Federation
(
WEF)
or
its
research
arm
(
WERF)
may
currently
be
working
on
producing
a
related
document,
and
EPA
could
coordinate
its
efforts
with
them.
Trading
is
being
considered
by
Region
10
as
a
way
to
control
nutrients
discharges;
EPA's
currently
available
information
on
trading
programs
could
help.
EAD
can
share
these
concerns
with
the
Office
of
Wastewater
Management
OWM)
to
assist
them
in
implementing
these
effluent
guidelines.

No
limits
for
nutrients
and
pathogens:
See
the
suggestions
discussed
in
the
previous
paragraph.

Changes
to
Control
Technologies
(
Recovery/
Reuse):
Some
operators
are
going
to
zero
discharge
and
selling
the
fish
by­
products
as
fish
meal
for
aquaculture
facilities.
European
countries
are
more
proactive
in
this
area,
and
may
have
additional
technology
options.
EPA's
FINAL
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August
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2004
Page
14
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29
currently
available
information
on
these
technologies
could
help.
EAD
can
share
these
concerns
with
the
OWM
to
assist
them
in
implementing
these
effluent
guidelines.

Summary
of
Potential
Solutions:
The
concerns
identified
for
this
industry
could
best
be
addressed
through
information
dissemination
and
outreach
by
EPA.
The
Agency
could
prepare
a
fact
sheet
with
answers
to
frequently
asked
questions
(
FAQs),
including
available
and
upcoming
guidance
and
other
resources.
This
information
could
be
posted
on
EPA's
web
site.
In
addition,
the
Agency
could
announce
the
availability
of
this
fact
sheet,
and
the
name
of
the
current
EAD
staff
available
to
answer
questions
at
the
regular
meetings
for
permit
writers
and
pretreatment
coordinators
held
by
OWM
and
also
through
email
alerts
to
the
EAD
stakeholders
mailing
list.
Finally,
due
to
the
presence
of
a
single
facility
discharging
the
bulk
of
the
TWPE,
EPA
could
also
provide
assistance
to
permit
writers
in
preparing
BPJ­
based
permits.
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2004
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Attachment
A
EPA
Databases
and
References
Used
in
this
Review
Overview
of
304(
m)
Planning
Process
CWA
Section
304(
m)(
1)
requires
EPA
to
establish
a
schedule
for
the
annual
review
and
revision
of
all
existing
effluent
guidelines
and
to
identify
categories
of
point
sources
discharging
toxic
or
non­
conventional
pollutants
for
which
EPA
has
not
published
effluent
guidelines.
To
accomplish
this
review,
EPA
conducted
a
screening­
level
analysis
using
readily
available
information
from
EPA's
Permit
Compliance
System
(
PCS)
and
Toxics
Release
Inventory
(
TRI)
databases.
EPA
estimated
the
mass
of
pollutants
discharged
from
each
category,
weighted
the
pollutant
releases
based
on
chemical
toxicity,
and
ranked
the
categories
based
on
the
toxicweighted
pollutant
releases.

In
addition
to
reported
discharges
in
PCS
and
TRI,
EPA
used
other
readily
available
data,
as
well
as
information
from
public
outreach,
including
industry
categories
recommended
by
stakeholders
for
regulatory
development
or
regulatory
revision,
to
evaluate
implementation
and
efficiency
considerations.

For
additional
details
on
EPA's
screening­
level
analysis
refer
the
following
documents
in
EPA
Docket
Number
OW­
2003­
0074:


Memorandum:
Description
and
Results
of
EPA
Methodology
to
Synthesize
Screening
Level
Results
for
the
Effluent
Guidelines
Program
Plan
for
2004/
2005,
DCN
548,
Section
3.0;


Development
of
PCSLoads
2000,
DCN
620,
Section
2.1.2
(
this
document
explains
how
pollutant
loads
were
calculated
from
PCS
data);
and

Evaluation
of
RSEI
Model
Runs,
DCN
618,
Section
2.1.1.

Information
from
EPA's
Permit
Compliance
System
(
PCS)
and
Toxics
Release
Inventory
(
TRI)
databases
were
used
to
create
the
PCSLoads2000
and
TRIReleases2000
databases.
These
databases
were
the
primary
source
of
information
used
to
conduct
this
review.
Since
this
industry
ranked
low
during
the
screening
phase,
however,
EPA
did
not
verify
any
of
the
information
reported
to
PCS
and
TRI,
and
has
used
it
as
reported.

TRIReleases2000
The
Toxic
Release
Inventory
(
TRI)
is
the
major
source
of
data
for
the
TRIReleases2000
database.
TRI
is
the
common
name
for
Section
313
of
the
Emergency
Planning
and
Community
FINAL
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2004
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Right­
to­
Know
Act
(
EPCRA).
Each
year,
facilities
that
meet
certain
thresholds
must
report
their
releases
and
other
waste
management
activities
for
listed
toxic
chemicals.
That
is,
facilities
must
report
the
quantities
of
toxic
chemicals
recycled,
collected
and
combusted
for
energy
recovery,
treated
for
destruction,
or
disposed
of.
A
separate
report
must
be
filed
for
each
chemical
that
exceeds
the
reporting
threshold.
The
TRI
list
of
chemicals
for
reporting
year
2000
includes
more
than
600
chemicals
and
chemical
categories.
For
this
review,
EPA
used
data
for
reporting
year
2000,
because
they
were
the
most
recent
available
at
the
time
the
review
began.

There
are
three
criteria
that
a
facility
must
meet
to
be
required
to
submit
a
TRI
report
for
that
reporting
year.
The
criteria
are:

(
1)
SIC
Code
Determination:
Facilities
in
SIC
Codes
20
through
39,
seven
additional
SIC
codes
outside
this
range,
and
federal
facilities
must
concern
themselves
with
TRI
reporting.
EPA
rarely
checks
or
refutes
facility
claims
regarding
the
SIC
code
identification.
The
primary
SIC
code
determines
TRI
reporting.

(
2)
Number
of
Employees:
Facilities
must
have
10
or
more
full­
time
employees
or
their
equivalent.
EPA
defines
a
"
full­
time
equivalent"
as
a
person
that
works
2,000
hours
in
the
reporting
year
(
there
are
several
exceptions
and
special
circumstances
that
are
well­
defined
in
the
TRI
reporting
instructions).

(
3)
Activity
Thresholds:
If
the
facility
is
in
a
covered
SIC
code
and
has
10
or
more
full­
time
employee
equivalents
it
must
conduct
an
activity
threshold
analysis
for
every
chemical
and
chemical
category
on
the
current
TRI
list.
The
facility
must
determine
whether
it
manufactures,
processes,
OR
otherwise
uses
each
chemical
at
or
above
the
appropriate
activity
threshold.
Reporting
thresholds
are
not
based
on
the
amount
of
release.
All
TRI
thresholds
are
based
on
mass,
not
concentration.
Different
thresholds
apply
for
persistent
bioaccumulative
toxic
(
PBT)
chemicals
than
for
non­
PBT
chemicals.

In
TRI,
facilities
report
annual
loads
released
to
the
environment
of
each
toxic
chemical
or
chemical
category
that
meets
reporting
requirements.
They
must
report
onsite
releases
to
air,
receiving
streams,
disposal
to
land,
underground
wells,
and
several
other
categories.
They
must
also
report
the
amount
of
toxic
chemicals
in
wastes
transferred
to
off­
site
locations,
including
discharges
to
POTWs
and
other
off­
site
locations,
such
as
commercial
waste
disposal
facilities.

For
this
review,
EPA
focused
on
the
amount
of
chemicals
facilities
reported
either
discharging
directly
to
a
receiving
stream
or
transferring
to
a
publicly
owned
treatment
works
(
POTW).
For
facilities
discharging
directly
to
a
stream,
the
loads
were
taken
directly
from
the
reported
TRI
data
for
calendar
year
2000.
For
facilities
that
transfer
toxic
chemicals
to
POTWs,
EPA
first
adjusted
the
TRI
pollutant
loads
reported
to
be
transferred
to
POTWs
to
account
for
pollutant
removal
that
occurs
at
the
POTW
prior
to
discharge
to
the
receiving
stream.
This
adjustment
was
made
using
POTW
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removal
efficiencies
from
EPA's
Risk
Screening
Environmental
Indicators
(
RSEI)
model
(
see
Section
2.1.1
of
the
docket
for
more
information
on
TRI
and
the
RSEI
model).

Reporting
facilities
are
not
required
to
sample
and
analyze
wastestreams
to
determine
the
quantities
of
toxic
chemicals
released.
They
may
estimate
releases
based
on
mass
balance
calculations,
published
emission
factors,
site­
specific
emission
factors,
or
other
approaches.
Facilities
are
required
to
indicate,
by
a
reporting
code,
the
basis
of
their
release
estimate.
TRI's
reporting
guidance
is
that
for
chemicals
reasonably
expected
to
be
present
but
measured
below
the
detection
limit,
facilities
should
use
one
half
the
detection
limit
to
estimate
the
mass
released.
The
guidance
is
slightly
different
for
dioxins
and
dioxin­
like
compounds
in
that
it
allows
nondetects
to
be
treated
as
zero.

TRI
provides
the
option
for
facilities
to
report
releases
as
specific
numbers
or
as
ranges,
if
appropriate.
Specific
estimates
are
encouraged
if
data
are
available
to
ensure
the
accuracy;
however,
EPA
allows
facilities
to
report
releases
in
the
following
ranges:
1
to
10
pounds,
11
to
499
pounds,
and
500
to
999
pounds.
For
this
analysis,
EPA
used
the
mid­
point
of
each
reported
range
to
represent
a
facility's
releases.

EPA
weighted
the
direct
and
indirect
pollutant
releases
to
surface
waters
using
toxic
weighting
factors
(
TWFs)
developed
by
Office
of
Water/
Engineering
and
Analysis
Division
(
EAD),
to
calculate
toxic
weighted
pound
equivalents
(
TWPE)
for
each
reported
release.
See
4.2.3
and
4.2.4
for
more
discussion
of
TWFs
and
calculation
of
TWPE.
EPA
compiled
data
taken
from
TRI,
the
adjusted
releases
from
POTWs
to
surface
waters,
the
calculated
TWPE,
and
the
relationship
between
SIC
codes
and
point
source
category
into
a
Microsoft
Access
 
database
named
TRIReleases2000.
Some
corrections
were
made
to
this
database
as
further
study
was
conducted
on
the
TRI
data.
Limitations
of
TRI
are
discussed
in
Section
IV
of
the
Technical
Support
Document
for
this
planning
process.

PCSLoads2000
The
Permit
Compliance
System
(
PCS)
is
the
major
source
of
data
for
the
PCSLoads2000
database.
PCS
is
a
computerized
management
information
system
maintained
by
EPA's
Office
of
Enforcement
and
Compliance
Assurance
(
OECA).
It
was
created
to
track
permit,
compliance,
and
enforcement
status
of
facilities
regulated
by
the
National
Pollutant
Discharge
Elimination
System
(
NPDES)
program
under
the
Clean
Water
Act
(
CWA).

More
than
65,000
industrial
facilities
and
water
treatment
plants
have
obtained
permits
for
water
discharges
of
regulated
pollutants.
To
provide
an
initial
framework
for
setting
permit
issuance
priorities,
EPA
developed
a
major/
minor
classification
system
for
industrial
and
municipal
wastewater
discharges.
Major
discharges
almost
always
have
the
capability
to
impact
receiving
waters
if
not
controlled
and,
therefore,
have
been
accorded
more
regulatory
attention
than
minor
discharges.
There
are
approximately
6,400
facilities
(
including
sewerage
systems)
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with
major
discharges
for
which
PCS
has
extensive
records.
Permitting
authorities
classify
discharges
as
major
based
on
an
assessment
of
six
characteristics:

(
1)
toxic
pollutant
potential;
(
2)
ratio
of
discharge
flow
to
stream
flow;
(
3)
conventional
pollutant
loading;
(
4)
public
health
impact;
(
5)
water
quality
factors;
and
(
6)
proximity
to
coastal
waters.

Facilities
with
major
discharges
must
report
compliance
with
NPDES
permit
limits
via
monthly
Discharge
Monitoring
Reports
(
DMRs)
submitted
to
the
permitting
authority.
The
permitting
authority
enters
the
reported
DMR
data
into
PCS,
including
the
type
of
violation
(
if
any),
concentration
and
quantity
values,
and
the
Quarterly
Non­
Compliance
Report
(
QNCR)
indicators.
Minor
discharges
may,
or
may
not,
adversely
impact
receiving
water
if
not
controlled.
Therefore,
EPA
does
not
require
DMRs
for
facilities
with
minor
discharges.
For
this
reason,
the
PCS
database
includes
data
only
for
a
limited
set
of
minor
dischargers
when
the
states
choose
to
include
these
data.
As
a
consequence,
extensive
data
are
not
available
for
minor
discharges
in
PCS.

Parameters
in
PCS
include
water
quality
parameters
(
such
as
pH
and
temperature),
specific
chemicals,
bulk
parameters
(
such
as
BOD
5
and
TSS),
and
flow
rates.
Although
other
pollutants
may
be
discharged,
PCS
only
contains
data
for
the
parameters
identified
in
the
facility's
NPDES
permit.
Facilities
typically
report
monthly
average
pounds
per
day
discharged,
but
also
report
daily
maxima,
and
pollutant
concentrations.

For
this
review,
EPA
used
data
for
reporting
year
2000,
to
correspond
to
the
data
obtained
from
TRI.
EPA
used
its
Effluent
Data
Statistics
(
EDS)
system
program
to
calculate
annual
pollutant
discharges
using
the
monthly
reports
in
PCS.
Because
units
of
measure
vary
widely
in
PCS,
EPA
developed
the
EDS
system
to
estimate
mass
loadings
based
on
data
stored
in
PCS.
The
EDS
system
uses
existing
PCS
reported
mass
loading
values
or
multiplies
reported
discharge
flows
and
effluent
concentrations
to
estimate
loadings
for
each
outfall
(
discharge
pipe),
taking
into
account
the
various
units
of
concentration
and
flow
rates.

Where
concentrations
were
reported
as
below
detection
limit
(
BDL)
EPA
assumed
the
parameter
concentration
was
equal
to
zero
for
parameters
never
detected
by
the
facility
in
2000.
For
parameters
sometimes
detected
and
sometimes
not,
the
"
BDL"
concentration
was
set
equal
to
half
of
the
detection
limit.
.
The
EDS
system
program
sums
the
monthly
loads
to
calculate
annual
discharges,
interpolating
(
using
average
reported
loads)
for
months
with
missing
reports.

EPA
weighted
the
calculated
annual
pollutant
discharges
using
EAD's
TWFs
to
calculate
TWPE
for
each
reported
discharge,
as
it
did
for
the
reported
TRI
releases.
See
sections
4.2.3
and
4.2.4
for
more
discussion
of
TWFs
and
calculation
of
TWPE.
EPA
compiled
data
taken
from
FINAL
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PCS,
the
calculated
TWPE,
and
the
relationship
between
SIC
codes
and
point
source
category
into
a
Microsoft
Access
 
database
named
PCSLoads2000.
As
further
study
was
conducted
on
the
PCS
data,
some
corrections
were
made.

Other
Information
Sources
In
addition
to
TRI
and
PCS,
EPA
used
the
following
sources
of
information
in
its
review
of
this
industry:

°
1997
Economic
Census
data;
and
2002
Economic
Census
data.

°
Contacts
with
reporting
facilities
to
verify
reported
releases
and
facility
categorization.

°
US
EPA,
1974.
Development
Document
for
Effluent
Limitations
Guidelines
and
New
Source
Performance
Standards
for
the
Catfish,
Crab,
Shrimp,
and
Tuna
Segment
of
the
Canned
and
Preserved
Seafood
Processing
Point
Source
Category.
440174020a.

°
US
EPA,
1975.
Development
Document
for
Effluent
Guidelines
and
New
Source
Performance
Standards
for
the
Fish
Meal,
Salmon,
Bottom
Fish,
Clam,
Oyster,
Sardine,
Scallop,
Herring,
and
Abalone
Segment
of
the
Canned
and
Preserved
Fish
and
Seafood
Processing
Industry
Point
Source
Category.
440175041a.

°
Anderson,
Erik
and
Jerpersen,
Claus,
1995.
More
Food,
Less
Waste
in
Seafood
Processing.
Accessed
at
<
http://
www.
p2pays.
org/
ref/
13/
12932.
pdf>
on
July
7,
2004.

°
Driscoll,
Terence
P,
1990.
Waste
Minimization
and
Product
Recovery
in
the
Crabmeat
Processing
Industry.
Accessed
at
<
http://
www.
p2pays.
org/
ref/
13/
12931.
pdf>
on
July
7,
2004.

°
Carawan,
Roy
E.
Preventing
Pollution
in
Shrimp
Processing.
Accessed
at
<
http://
www.
p2pays.
org/
ref/
01/
00234.
pdf>
on
July
7,
2004.

°
Pacific
Northwest
Pollution
Prevention
Research
Center,
1993.
Pollution
Prevention
Opportunities
in
the
Fish
Processing
Industry.
Accessed
at
<
http://
www.
p2pays.
org/
ref/
01/
00234.
pdf>
on
July
7,
2004.

°
US
Census
Bureau.
Comparative
Statistics
for
the
United
States.
Accessed
at
<
http://
www.
census.
gov>
on
July
6,
2004.
FINAL
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August
12,
2004
Page
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29
Attachment
B
Point
Source
Categories
Identified
Solely
Through
Factor
4
Industry
Formal
Comment
Process
Previous
Suggestions
(
Sec.
2.4)
Draft
Strategy
Outreach
Comments
on
Draft
Strategy
(
Sec.
2.2)
Comments
on
2002/
2003
Plan
(
Sec.
2.3)
Permitting
Authorities
(
Sec.
2.5)
AMSA
&
ASIWPCA
(
Sec.
2.6)

Coal
Mining



Coil
Coating

Dairy
Products
Processing

Electrical
and
Electronic
Components

Fruits
and
Vegetable
Processing


Metal
Molding
and
Casting




Mineral
Mining
and
Processing

Seafood
Processing



FINAL
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August
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29
Attachment
C
Applicability
and
Regulatory
History
Applicability
of
40
CFR
Part
408
Subpart
A
 
Farm­
Raised
Catfish
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
farm­
raised
catfish
by
existing
facilities
which
process
more
than
1362
kg
(
3000
pounds)
of
raw
material
per
day
on
any
day
during
a
calendar
year
and
all
new
sources.

Subpart
B
 
Conventional
Blue
Crab
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
blue
crab
in
which
manual
picking
or
separation
of
crab
meat
from
the
shell
is
utilized.
The
effluent
limitations
contained
in
this
subpart
B
are
applicable
to
existing
facilities
processing
more
than
1362
kg
(
3000
pounds)
of
raw
material
per
day
on
any
day
during
a
calendar
year
and
all
new
sources.

Subpart
C
 
Mechanized
Blue
Crab
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
blue
crab
in
which
mechanical
picking
or
separation
of
crab
meat
from
the
shell
is
utilized.

Subpart
D
 
Non­
Remote
Alaskan
Crab
Meat
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing,
in
non­
remote
Alaska,
of
dungeness,
tanner,
and
king
crab
meat.
The
effluent
limitations
contained
in
this
subpart
D
are
applicable
to
facilities
located
in
population
or
processing
centers
including
but
not
limited
to
Anchorage,
Cordova,
Juneau,
Ketchikan,
Kodiak,
and
Petersburg.

Subpart
E
 
Remote
Alaskan
Crab
Meat
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing,
in
remote
Alaska,
of
dungeness,
tanner,
and
king
crab
meat.
The
effluent
limitations
contained
in
subpart
E
are
applicable
to
facilities
not
covered
under
subpart
D.

Subpart
F
 
Non­
Remote
Alaskan
Whole
Crab
and
Crab
Section
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing,
in
nonremote
Alaska,
of
dungeness,
tanner
and
king
whole
crab
and
crab
sections.
The
effluent
limitations
contained
in
this
subpart
F
are
applicable
to
facilities
located
in
population
or
processing
centers
including
but
not
limited
to
Anchorage,
Cordova,
Juneau,
Ketchikan,
Kodiak,
and
Petersburg.

Subpart
G
 
Remote
Alaskan
Whole
Crab
and
Crab
Section
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing,
in
remote
Alaska,
of
dungeness,
tanner,
and
king
whole
crab
and
crab
sections.
The
effluent
limitations
contained
in
this
subpart
G
are
applicable
to
facilities
not
covered
under
subpart
F
of
this
part.
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Subpart
H
 
Dungeness
and
Tanner
Crab
Processing
in
the
Contiguous
States
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
dungeness
and
tanner
crab
in
the
contiguous
States.

Subpart
I
 
Non­
Remote
Alaskan
Shrimp
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
shrimp
in
non­
remote
Alaska.
The
effluent
limitations
contained
in
this
subpart
I
are
applicable
to
facilities
located
in
population
or
processing
centers
including
but
not
limited
to
Anchorage,
Cordova,
Juneau,
Ketchikan,
Kodiak,
and
Petersburg.

Subpart
J
 
Remote
Alaskan
Shrimp
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
shrimp
in
remote
Alaska.
The
effluent
limitations
contained
in
this
subpart
J
are
applicable
to
facilities
not
covered
under
subpart
I
of
this
part.

Subpart
K
 
Northern
Shrimp
Processing
in
the
Contiguous
States
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
shrimp
in
the
Northern
contiguous
States,
including
Washington,
Oregon,
California,
Maine,
New
Hampshire,
and
Massachusetts.
The
effluent
limitations
contained
in
this
subpart
K
are
applicable
to
existing
facilities
processing
more
than
908
kg
(
2000
pounds)
of
raw
material
per
day
on
any
day
during
a
calendar
year
and
all
new
sources.

Subpart
L
 
Southern
Non­
Breaded
Shrimp
Processing
in
the
Contiguous
States
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
nonbreaded
shrimp
in
the
Southern
contiguous
States,
including
North
and
South
Carolina,
Georgia,
Florida,
Alabama,
Mississippi,
Louisiana,
and
Texas.
The
effluent
limitations
contained
in
this
subpart
L
are
applicable
to
existing
facilities
processing
more
than
908
kg
(
2000
pounds)
of
raw
material
per
day
on
any
day
during
a
calendar
year
and
all
new
sources.

Subpart
M
 
Breaded
Shrimp
Processing
in
the
Contiguous
States
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
breaded
shrimp
in
the
contiguous
States
by
existing
facilities
processing
more
than
908
kg
(
2000
pounds)
of
raw
material
per
day
on
any
day
during
a
calendar
year
and
all
new
sources.

Subpart
N
 
Tuna
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
tuna.

Subpart
O
 
Fish
Meal
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
menhaden
on
the
Gulf
and
Atlantic
Coasts
and
the
processing
of
anchovy
on
the
West
Coast
into
fish
meal,
oil
and
solubles.

Subpart
P
 
Alaskan
Hand­
Butchered
Salmon
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
hand­
butchering
of
salmon
in
Alaska.
FINAL
DRAFT
Seafood
Processing
August
12,
2004
Page
23
of
29
Subpart
Q
 
Alaskan
Mechanized
Salmon
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
mechanized
butchering
of
salmon
in
Alaska.

Subpart
R
 
West
Coast
Hand­
Butchered
Salmon
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
hand­
butchering
of
salmon
on
the
West
Coast.

Subpart
S
 
West
Coast
Mechanized
Salmon
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
mechanized
butchering
of
salmon
on
the
West
Coast.

Subpart
T
 
Alaskan
Bottom
Fish
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
bottom
fish
such
as
halibut
in
Alaska.

Subpart
U
 
Non­
Alaskan
Conventional
Bottom
Fish
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
bottom
fish
outside
of
Alaska
in
which
the
unit
operations
are
carried
out
predominately
through
manual
methods.
However,
the
use
of
scaling
machines
and/
or
skinning
machines
are
considered
to
be
normal
practice
within
this
subcategory.
The
provisions
of
this
subpart
apply
to
the
processing
of
currently,
commercially
processed
species
of
bottom
fish
such
as
flounder,
ocean
perch,
haddock,
cod,
sea
catfish,
sole,
halibut,
and
rockfish.
These
provisions
apply
to
existing
facilities
processing
more
than
1816
kg
(
4000
pounds)
of
raw
material
per
day
on
any
day
during
a
calendar
year
and
all
new
sources.

Subpart
V
 
Non­
Alaskan
Mechanized
Bottom
Fish
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
bottom
fish
outside
of
Alaska
in
which
the
unit
operations
(
particularly
the
butchering
and/
or
filleting
operations)
are
carried
out
predominately
through
mechanized
methods.
The
provisions
of
this
subpart
apply
to
the
processing
of
bottom
fish
such
as
whiting
and
croaker.

Subpart
W
 
Hand­
Shucked
Clam
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
existing
hand­
shucked
clam
processing
facilities
which
process
more
than
1816
kg
(
4000
pounds)
of
raw
material
per
day
on
any
day
during
a
calendar
year
and
all
new
sources.

Subpart
X
 
Mechanized
Clam
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
mechanized
clam
processing.

Subpart
Y
 
Pacific
Coast
Hand­
Shucked
Oyster
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
existing
Pacific
Coast
handshucked
oyster
processing
facilities
which
process
more
than
454
kg
(
1000
pounds)
of
product
per
day
on
any
day
during
a
calendar
year
and
all
new
sources.
FINAL
DRAFT
Seafood
Processing
August
12,
2004
Page
24
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29
Subpart
Z
 
Atlantic
and
Gulf
Coast
Hand­
Shucked
Oyster
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharge
resulting
from
existing
hand­
shucked
oyster
processing
facilities
on
the
Atlantic
and
Gulf
Coasts
which
process
more
than
454
kg
(
1000
pounds)
of
product
per
day
on
any
day
during
a
calendar
year
and
all
new
sources.

Subpart
AA
 
Steamed
and
Canned
Oyster
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
oysters
which
are
mechanically
shucked.

Subpart
AB
 
Sardine
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
canning
of
sardines
or
sea
herring
for
sardines.
These
provisions,
however,
do
not
cover
the
relatively
new
steaking
operation
in
which
cutting
machines
are
used
for
preparing
fish
steaks.

Subpart
AC
 
Alaskan
Scallop
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
scallops
in
Alaska.

Subpart
AD
 
Non­
Alaskan
Scallop
Processing
Subcategory.
With
the
exception
of
land­
based
processing
of
calico
scallops,
the
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
scallops
outside
of
Alaska.

Subpart
AE
 
Alaskan
Herring
Fillet
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
herring
fillets
in
Alaska.

Subpart
AF
 
Non­
Alaskan
Herring
Fillet
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
herring
fillets
outside
of
Alaska.

Subpart
AG
 
Abalone
Processing
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
processing
of
abalone
in
the
contiguous
states.

REGULATORY
BACKGROUND
Regulatory
History
Effluent
limitations
for
BPT,
BAT,
and
NSPS
were
promulgated
for
the
catfish,
crab,
shrimp,
and
tuna
segments
of
the
industry
(
Subparts
A­
N)
in
1974.

Effluent
limitations
for
BPT,
BAT,
and
NSPS
were
promulgated
for
the
fish
meal,
bottom
fish,
clam,
oyster,
sardine,
scallop,
herring,
and
abalone
segments
of
the
industry
(
Subparts
O­
AG)
in
1975.

Existing
Limitations
FINAL
DRAFT
Seafood
Processing
August
12,
2004
Page
25
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29
The
parameters
determined
to
be
of
significant
importance
for
seafood
processing
are
BOD,
TSS,
and
oil
and
grease.
The
technology
basis
for
existing
effluent
guidelines
includes
screening,
dissolved
air
flotation,
and
biological
treatment.

Coliform
Test
as
Indicator:
EPA
considered
including
a
coliform
test
as
an
indicator
of
fecal
content
in
seafood
processing
wastewater
(
Phase
I
TDD,
pg
213).
Coliform
organisms,
however,
are
not
naturally
found
in
the
intestines
of
cold
blooded
animals.
Therefore,
no
correlation
exists
between
fish
fecal
contamination
and
fecal
coliform
levels
in
fish
processing
wastewater.
An
EPA­
sponsored
study
of
fecal
coliform
levels
in
fish
processing
wastewater
conducted
in
1973
concluded
that
the
coliform
test
produced
extremely
inconsistent
results.
Based
on
the
results
of
the
study,
EPA
decided
not
to
include
fecal
coliform
in
the
list
of
parameters
selected
for
regulation.

Kjeldahl
Test
for
Monitoring
Nitrogen:
EPA
considered
including
a
kjeldahl
test
for
monitoring
organic
nitrogen
and
ammonia
levels
in
fish
processing
wastewater.
EPA
did
not
include
a
monitoring
requirement
for
total
kjedahl
nitrogen
(
TKN)
because
the
removal
of
nitrogen
in
physical/
chemical
and
biological
treatment
had
yet
to
be
evaluated.
Furthermore,
there
was
no
demonstrated
need
for
a
separate
treatment
technology
specific
to
nitrogen
compounds.
FINAL
DRAFT
Seafood
Processing
August
12,
2004
Page
26
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29
Table
C­
1.
Effluent
Guidelines
for
Canned
and
Preserved
Seafood
Processing
Part
408
Subparts
BOD
5
­
30­
Day
Average
(
kg/
kkg)
TSS
­
30­
Day
Average
(
kg/
kkg)
Oil
and
Grease
­
30­
Day
Average
(
kg/
kkg)

BPT
BAT
NSPS
BPT
BAT
NSPS
BPT
BAT
NSPS
Farm­
raised
catfish:
A
NA
2.3
2.3
9.2
5.7
5.7
3.4
0.45
0.45
Crab:
B,
C,
D,
F,
H
NA
0.15
to
2.5
2.5
to
4.1b
0.74
to
12
0.23
to
6.3
0.45
to
6.3
0.20
to
4.2
0.045
to
1.3
0.065
to
1.3
Remote
Alaskan
crab:
E,
G
NA
NA
NA
*
3.3
to
5.3
3.3
to
5.3
*
0.36
to
0.52
0.36
to
0.52
Shrimp:
I,
K,
L,
M
NA
10
to
28
25
to
62b
38
to
210
3.4
to
18
10
to
180
12
to
17
1.0
to
3.8
1.5
to
15
Remote
Alaskan
shrimp:
J
NA
NA
NA
*
180
180
*
15
15
Tuna:
N
9.0
0.62
8.1
3.3
0.62
3.0
0.84
0.077
0.76
Fish
meal:
O
3.5
2.6
2.9
1.3
1.3
1.3
0.63
0.63
0.63
Salmon:
P,
Q
(
non­
remote),
R,
S
NA
1.0
to
13a
1.4
to
32b
1.4
to
22
0.12
to
2.2
0.37
to
21
0.17
to
10
0.018
to
1.0
0.023
to
10
Remote
Alaskan
salmon:
Q
*
NA
*
*
21
*
*
10
*

Bottom
fish:
T,
U,
V
NA
0.58
to
5.3a
0.58
to
7.4b
2.1
to
14
0.73
to
1.1
0.73
to
2.5
0.55
to
5.7
0.03
to
0.34
0.03
to
0.39
Clam:
W,
X
NA
5.7a
5.7b
15
to
18
4.4
to
17
4.4
to
17
0.23
to
0.97
0.092
to
0.21
0.092
to
0.21
Oyster:
Y,
Z,
AA
NA
17a
17b
15
to
190
15
to
39
15
to
39
0.70
to
1.7
0.42
to
1.6
0.42
to
1.6
Sardine:
AB
NA
NA
NA
10
to
16
10
10
1.4
to
2.8
5.2
0.57
Scallop:
AC,
AD
NA
NA
NA
1.4
1.4
1.4
0.24
0.23
0.23
Herring
filet:
AE
(
non­
remote),
AF
NA
6.2a
15b
24
1.8
5.2
to
18
10
0.73
1.1
to
7.3
Alaskan
herring
filets
(
remote):
AE
*
NA
*
*
18
*
*
7.3
*

Alabone:
AG
NA
NA
NA
15
14
14
1.4
1.3
1.3
Sources:
Technical
Development
Documents,
1974
and
1975
*
No
pollutants
exceeding
1.27cm
in
any
dimension
may
be
discharged.

NA
indicates
that
no
limitations
were
established.

aThere
are
no
BAT
limits
for
BOD
for
Subparts
P,
T,
W,
Y,
and
Z.

bThere
are
no
NSPS
for
BOD
for
Subparts
D,
F,
I,
P,
Q,
T,
W,
Y,
Z,
and
AE.
FINAL
DRAFT
Seafood
Processing
August
12,
2004
Page
27
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29
Attachment
D
PCS
Discharges
SIC
NPDES
ID
NAME
CITY
Flow
(
MGD)
POUNDS/
YR
TWPE
Percent
of
Total
SIC
TWPE
Cumulative
Percent
of
Total
SIC
TWPE
2091
PR0023043
MAYAGUEZ
WATER
TREATMENT
CO
IN
MAYAGUEZ
2
2,486,231
18,897
100%
100%

2091
OH0003298
CAMPBELL
SOUP
COMPANY
NAPOLEON
5
411,688
1
2091
AK0028657
UNISEA
INC
DUTCH
HARBOR
2
1,346
2091
AK0000272
ALYESKA
SEAFOODS
INC
UNALASKA
1
13,927,171
2091
TOTAL
10
16,826,436
18,898
2092
AK0037303
TRIDENT
SEAFOODS
CORP
AKUTAN
3
85,141,866
54
86%
86%

2092
RI0001121
BLOUNT
SEAFOOD
CORPORATION
WARREN
0.084
1,209,057
9
14%
100%

2092
TOTAL
3
86,350,923
63
FINAL
DRAFT
Seafood
Processing
August
12,
2004
Page
28
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29
Attachment
E
TRI
Discharges
­
Only
Direct
Discharges
Reported
SIC
Code
Facility
TRI
ID
Facility
Name
Facility
City
Facility
State
Total
lbs
Total
TWPE
Percent
Total
of
SIC
TWPE
Cumulative
Percent
Total
of
SIC
TWPE
2092
99692NSNC
POUCH
UNISEA
INC.
DUTCH
HARBOR
AK
8,546
13
65%
65%

2092
38751DLTPRINDIA
DELTA
PRIDE
CATFISH
INC.
INDIANOLA
MS
45,016
7
35%
100%

2092
TOTAL
53,562
20
FINAL
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Seafood
Processing
August
12,
2004
Page
29
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29
Attachment
F
Reported
Pollutant
Loadings
SIC
Pollutant
Name
CAS
Pollutan
t
Group
Code
PCS
Facilities
Reporting
Pollutant
PCS
Pounds
PCS
TWPE
TRI
Direct
Facilities
Reporting
Pollutant
TRI
Direct
Pounds
TRI
Direct
TWPE
2091
TOTAL
SUSPENDED
SOLIDS
C009
CP
5
5,239,353
2091
BOD
5­
DAY
(
CARBONACEOUS)
C003
CP
5
9,846,560
2091
OIL
AND
GREASE
C035
CP
2
1,020,938
2091
SUM
OF
CONVENTIONAL
POLLUTANTS
16,106,851
0
0
0
2091
NITROGEN,
NITRATE
TOTAL
(
AS
N)
14797558
NC
1
431,822
27
2091
PHOSPHORUS
7723140
NC
1
8,868
2091
TOTAL
KJELDAHL
NITROGEN
C021
NC
1
260,056
2091
TOTAL
RECOVERABLE
PHENOLICS
C020
NC
2
23
1
2091
AMMONIA
AS
NITROGEN
7664417
NC
1
340
1
2091
TOTAL
SULFIDE
18496258
NC
1
6,728
18,842
2091
SUM
OF
NONCONVENTIONAL
POLLUTANTS
707,836
18,870
0
0
2091
LEAD
7439921
PP
1
7
17
2091
COPPER
7440508
PP
2
9
6
2091
ZINC
7440666
PP
1
122
6
2091
SUM
OF
PRIORITY
POLLUTANTS
138
28
0
0
2092
TOTAL
SUSPENDED
SOLIDS
C009
CP
2
33,433,112
2092
BOD
5­
DAY
(
CARBONACEOUS)
C003
CP
2
38,270,934
2092
OIL
AND
GREASE
C035
CP
1
14,397,009
2092
SUM
OF
CONVENTIONAL
POLLUTANTS
86,101,055
0
0
0
2092
AMMONIA
AS
NITROGEN
7664417
NC
1
4,648
9
2
11,388
17
2092
CHLORINE,
TOTAL
RESIDUAL
7782505
NC
3
111
54
2092
NITROGEN,
NITRATE
TOTAL
(
AS
N)
14797558
NC
1
30
0.0019
1
42,174
3
2092
NITROGEN,
NITRITE
TOTAL
(
AS
N)
14797650
NC
1
50
2092
PHOSPHORUS
7723140
NC
1
7,354
2092
TOTAL
ORGANIC
CARBON
(
TOC)
C012
NC
1
215,771
2092
SUM
OF
NONCONVENTIONAL
POLLUTANTS
227,965
63
53,562
20
