Report to the Record
                             Profile of the Alaska Seafood
Processing Industry

                                           U.S. Environmental Protection Agency
                                                        Office of Water (4303T)
                                                     1200 Pennsylvania Ave., NW
                                                           Washington, DC 20460

                                                                    August 2013

                               TABLE OF CONTENTS
1.0	Background	1
1.1.	History of the Regulation	1
1.2.	Current Administration of the ELG in Alaska	3
1.3.	Reconsideration of the Alaskan Seafood Processing Subcategories	3
1.4.	Organization of the Industry Profile	3
2.0	Overview of the seafood processing industry	4
2.1.	Description of the Industry	4
2.2.	Significance of the Alaska Fisheries and Seafood Processing Industry in the Global, U.S., and Regional Economies	4
2.2.1.	Fisheries	4
2.2.2.	Seafood Processing	6
2.3.	Overview of the Seafood Processing Industry in Alaska	7
2.4.	The Major Alaskan Fisheries and their impact on Seafood Processing Finances	8
3.0	Alaska Seafood Processing Facilities and Firms in the Petitioning Non-Remote Processing Locations and Additional Remote Processing Locations of Interest	11
3.1.	Overview Of Facilities and Firms	12
3.1.1.	Petitioning Non-Remote Processing Location Facilities	13
<IP_ADDRESS>.	Cordova	13
<IP_ADDRESS>.	Juneau	17
<IP_ADDRESS>.	Ketchikan	17
<IP_ADDRESS>.	Petersburg	18
3.1.2.	Processing Locations of Interest Currently Classified as Remote	18
<IP_ADDRESS>.	Dutch Harbor	19
<IP_ADDRESS>.	Kenai Peninsula	19
<IP_ADDRESS>.	Sitka	21
3.2.	Firms Owning Facilities in the Petitioning Non-Remote Processing Locations and Remote Locations of Interest	21
3.2.1.	Firms Owning Petitioning Processing Location Facilities	24
3.2.2.	Other Firms Owning Remote Facilities in Procressing Locations of Interest (Dutch Harbor, Kenai Peninsula, Sitka)	25
<IP_ADDRESS>.	Dutch Harbor	25
<IP_ADDRESS>.	Kenai Peninsula	26
<IP_ADDRESS>.	Sitka	27
4.0	Current Industry Practices For Managing Waste	27
4.1.	General Waste Management Practices	27
4.2.	Seafood By-products	28
4.2.1.	Fishmeal	28
4.2.2.	Bone Meal	29
4.2.3.	Fish Oil	29
4.2.4.	Hydrolyzed Protein	29
4.2.5.	Montlake Process	30
4.2.6.	Compost and Crop Nutrient	30
4.2.7.	Modified Silage	30
4.2.8.	Chondroitin Sulfate (CS)	30
4.2.9.	Dried Salmon Fish Heads	30
4.2.10.	Chitin	31
4.3.	Markets for Seafood Processing By-products	31
4.3.1.	Fishmeal	31
4.3.2.	Fish Oil	33
4.3.3.	Hydrolysate	34
5.0	Alaskan By-product Market Considerations	34
5.1.	Number of By-product Processing Facilities	34
5.2.	Current By-product Processing in The Petitioning Locations and  Additional Locations of Interest	37
5.2.1.	Status of By-product Recovery in the Petitioning Locations	37
<IP_ADDRESS>.	Cordova	37
<IP_ADDRESS>.	Juneau	38
<IP_ADDRESS>.	Petersburg	38
<IP_ADDRESS>.	Ketchikan	39
5.2.2.	Status of By-product Recovery in the Locations of Interest	39
<IP_ADDRESS>.	Dutch Harbor	39
<IP_ADDRESS>.	Kenai Peninsula	39
<IP_ADDRESS>.	Sitka	40
5.3.	Total Waste Available in Petition Processing Locations	40
5.4.	Waste utilization estimates	43
6.0	Comparing Potential Alaskan and Global Quantities of By-products	44
7.0	OTHER FACTORS AFFECTING processors in non-remote Processing  Locations	45
8.0	References	51

                                LIST OF TABLES
Table 1. 2008 Fish Production and Processing Overview	5
Table 2. Alaska Seafood Processing in the Context of Its Region and the U.S. Seafood Processing Industry	7
Table 3.  Facility Overview by Petitioning Locations and Locations of Interest	14
Table 4. Firms with Potentially Affected Petitioning Alaskan Processing Facilities and Those with Facilities in the Locations of Interest	22
Table 5. Facilities Producing Fishmeal and Fish Oil	36
Table 6. ADFG Regions Corresponding to Petitioning Locations	41
Table 7. Estimated Seafood Waste from Regions Surrounding Petitioning Processing Locations in 2008 (tons)	42
Table 8. Annual Salmon Waste Generated by Petitioning Areas and Areas of Interest 2005-2009	42
Table 9. 2009 Regional Salmon Harvests and Estimated Fishmeal and Oil Production (metric tons)	43
Table 10. Fishmeal and Fish Oil Production Estimates by Petitioning Locations and Additional  Locations of Interest	43
Table 11. Comparing Alaskan and Global Quantities of Seafood By-products	44
Table 12. Other Processors Closest to the Processors in Petitioning Locations and Locations of Interest	45
Table 13. Census Characterization of Petitioning Processor Communities from 2000 US Census	46
Table 14 Seafood Processing in the Context of Census Employment and Establishments	48
Table 15. Seafood Canning and Fresh/Frozen Processor Establishments and Employees [a]	50

                                LIST OF FIGURES
Figure 1. Alaska Fish Production as it Relates to Regional and National Production	6
Figure 2. 2008 Fish Landings and Ex-Vessel Values by Alaska Fishery	10
Figure 3.  Map of ADFG Harvest Areas with Seafood Processor Locations	12
Figure 4. Top International Fishmeal Producers 2006-2009	32
Figure 5. Comparing Global and Alaskan Potential Meal and Oil Production	45

Background
History of the Regulation
U.S. EPA is again considering finalizing a response to a petition on a final regulation and amending effluent limitations guidelines including numeric discharge limits on effluents from a subset of seafood processing facilities located in Alaska. This regulation, an effluent limitations guideline, or ELG, was originally promulgated in two phases in 1974 and 1975. In order to understand the regulation, it is necessary to know how the regulation defines the various seafood processing entities and the history of the regulatory process for this industry.
The two-phase rule (begun in 1974 and completed in 1975) (40 CFR Part 408) covers all seafood processors in the United States and has created a number of subcategories within the Seafood Processing Category. These subcategories generally relate to a number of factors, including geographic region, the type of processing methods employed, and type of fish or shellfish harvested. In this way, the rule was designed to take into account the unique characteristics of the seafood processing facilities, their locations, and how they process the seafood. Alaska seafood processors are divided into a number of subcategories. These subcategories include:
   # Non-remote Alaska Crabmeat Processing
   # Remote Alaska Crabmeat Processing
   # Non-remote Alaska Whole Crab and Crab Section Processing
   # Remote Alaska Whole Crab and Crab Section Processing
   # Non-remote Alaska Shrimp Processing
   # Remote Alaska Shrimp Processing
   # Alaska Hand-butchered Salmon Processing
   # Alaska Mechanized Salmon Processing
   # Alaska Bottom Fish Processing
   # Alaska Scallop Processing
   # Alaskan Herring Fillet Processing
Although, at first glance, it would appear that the terms "non-remote" and "remote" have a broad geographic definition, in fact, the terms are very specific. Non-remote seafood processors are located only in the following non-exclusive list of locations, or "processing locations:"
   # Anchorage
   # Cordova
   # Juneau
   # Kodiak
   # Ketchikan
   # Petersburg.
These six locations were classified in the regulation as non-remote locations generally on the basis of having greater economies of scale than those areas classified as "remote." All areas outside of these locations were classified as "remote." All seafood processors are subject to Best Practicable Control Technology Currently Available (BPT) regulations. For non-remote processors, BPT provides mass-based numeric limitations on total suspended solids (TSS), oil and grease, and a range for pH. Remote seafood processors are only required to meet size limitations on the wastes discharged with their effluent (that is, the solids in their wastes must be less than (1/2) inch in all dimensions prior to discharge).  The requirements to meet ELGs covering TSS, oil and grease, and pH are based on screening the wastewater.  Best Conventional Pollutant Control Technology (BCT) and New Source Performance Standards (NSPS) are set equal to BPT requirements for both remote and non-remote seafood processors. Best Available Technology Economically Achievable (BAT) regulations have been replaced by BCT effluent limitations for all of the subcategories.
It must be noted that EPA bases its effluent limitations guidelines and standards on a particular technology or set of technologies but does not require adoption of any particular technology to comply with ELGs. Once the limitations are established, the individual facilities may use any technology or set of technologies to meet the effluent limitations guidelines and standards. In addition, individual facilities can consider opportunities to work together and collectively take advantage of economies of scale.
At the time of the original rulemakings in 1974 and 1975, EPA made the distinction between remote and non-remote processors on the basis that waste disposal alternatives that might be available in some locations would not be available in all areas of Alaska. Furthermore, EPA determined that seafood processors that were not near large population centers or were not located near other seafood processors might be at an economic disadvantage.
The implementation of the rule was held up during a court challenge, in which EPA eventually prevailed. However, shortly after, in 1980, Pacific Seafood Processors Association; Morpac, Inc; Nefco-Fidalgo Packing Company; North Pacific Processors; E.C. Phillips and Son, Inc; Washington Fish & Oyster Company; and Whitney Fidalgo Seafoods petitioned the EPA to reconsider and modify the ELG. All non-remote regions except Kodiak were represented in this petition; processors in Kodiak complied with the BPT effluent limitations and thus no Kodiak establishments joined the petition. The petitioners claimed that the costs of achieving the BPT effluent limitations were not in proportion to the effluent reduction benefits for non-remote Alaska processing locations. The petitioners also requested that EPA suspend the regulations asserting that a record-breaking salmon season would occur in 1980, while also noting the timing for guideline implementation could also pose compliance problems for the industry. On May 19, 1980, EPA published a direct final rule suspending the BPT screening requirement for processors (45 FR 32675), based upon good cause. The suspension was intended to expire October 15, 1980.
On June 16, the petitioners filed a supplemental petition for modification, maintaining that Anchorage, Cordova, Juneau, Ketchikan, and Petersburg should be removed from the non-remote designation and requesting EPA provide further evidence regarding the costs and benefits of implementing the new BPT requirements. EPA published the supplemental petition in its entirety on August 7, 1980 (45 FR 52411). In January 1981, EPA proposed to grant the petition for Juneau (removing it from non-remote status) and deny the petition for the other petitioning communities (46 FR 2544). The proposed response also indicated the suspension of BPT for the petitioning non-remote Alaska seafood processors (51 FR 24974) would remain in effect until a final decision was reached. EPA also solicited comment on, but did not formally propose, adding Dutch Harbor and the Kenai Peninsula to the list of non-remote locations. EPA has not, however, made a final decision regarding the petition, and, therefore, the remote and non-remote designations, as well as BPT requirements for non-remote Alaska seafood processors, remain suspended. The suspension effectively requires all Alaskan seafood processors covered by the ELGs (with the exception of those in Kodiak) to meet the less stringent BPT effluent limitations based upon grinding for remote seafood processors, that is, waste size limits.
Current Administration of the ELG in Alaska
ELGs are administered through a system of permits, known as National Pollutant Discharge Elimination System (NPDES) permits.  With the exception of seafood processors in Kodiak and a few others, permits written for seafood processors in Alaska require processors to meet the BPT requirements for remote seafood processors. NPDES permits spell out the limitations specified by the ELGs, unless more restrictive limits are placed in the permits to meet state requirements or water quality needs. Thus, the limits cannot be less stringent than the ELG requirements, which in this case means less stringent than the BPT requirement for remote processors, due to the suspension of the non-remote designation. Until recently, EPA Region 10 managed the issuance of permits to all discharging facilities in Alaska, including seafood processors. However, in 2008, EPA transferred authority over the NPDES permitting program to the State of Alaska.  As such, the Alaska Department of Environmental Conservation (ADEC) issues NPDES permit to seafood processors discharging into state waters.  EPA retains authority to issue permits in offshore federal waters (i.e., waters more than 3 miles from the baseline).
The NPDES permit covering the majority of seafood processors in Alaska is the NPDES General Permit for Seafood Processors in Alaska (AKG-52-0000), which expired in 2006 but which continues to cover shorebased seafood processors until a new General Permit can be issued. This permit applies the remote ELGs which are the less stringent BPT effluent limitations based upon grinding.  Permitted seafood processors in Kodiak are authorized to discharge pursuant to the NPDES General Permit for Seafood Processors Operating Shorebased Facilities in Kodiak, Alaska (AKG528000FP).  The Kodiak permit is based on the non-remote numeric BPT effluent limitations.  Seafood processors in Dutch Harbor have been issued individual NPDES permits that contain more stringent limits based on a Total Maximum Daily Limit (TMDL) (including limits for Biological Oxygen Demand (BOD)). In addition, offshore seafood processors (i.e., processors operating more than one half nautical mile from shore) are covered by the Alaska Offshore Seafood Processors NPDES General Permit (AKG 523000) which applies the remote BPT effluent limitations based upon grinding.
Reconsideration of the Alaskan Seafood Processing Subcategories
EPA is again considering appropriate amendments to the regulations as described above.  EPA will consider the original proposal and comments received on that proposal, current information (collected from both secondary sources and recently received responses to a Section 308 survey questionnaire), and comments that will be received on the notice of data availability (NODA). As indicated in the proposal, EPA is reviewing the status of an additional three "remote" locations that might be considered for reassignment to the "non-remote" classification: Dutch Harbor, Sitka, and the Kenai Peninsula. Additional locations that have similar characteristics to facilities classified as non-remote, such as Naknek, also could be considered based upon data and information submitted with public comments on the NODA.
Organization of the Industry Profile
The purpose of this industry profile is to provide an understanding of the industry within Alaska as well as its importance within the United States and abroad.  Section 2 provides an overview of the industry and describes relevant global, national, regional, and state and local economic information. Section 3 provides information on the firms and facilities in the potentially affected non-remote areas, as well as information on those in the remote areas that EPA is considering adding to the list of non-remote locations. Section 4 then describes the current industry practices for managing fish wastes through discharge, offshore disposal, and by-product recovery, which is discussed in detail. Section 5 discusses the status of by-product recovery in the petitioning locations and additional locations of interest. Section 6 presents a comparison of potential Alaskan by-product recovery quantities to the global availability of by-products. In Section 7, the report discusses the role of species of fish processed and proximity of facilities in locations that may be considered non-remote in a possible final regulation to those that may remain remote. EPA also discusses the role of the seafood processing industry in the local economies of the non-remote petitioner communities.
Overview of the seafood processing industry
Description of the Industry
The seafood processing industry is a part of the wider food processing sector, a major category within the manufacturing sector of the economy.  The seafood processing industry acquires fresh fish or shellfish from harvesters, who typically operate as separate businesses within a non-manufacturing sector (the agriculture, forestry, fishing, and hunting sector), although some seafood processors operate large processing ships, which catch, process, and deliver seafood products as part of one operation.  When the processor acquires the fresh seafood from harvesters, the processor removes unwanted fish parts (such as skeletons, heads, or shells) before creating secondary, preserved products for both human and non-human consumption. The processes in which usable fish products are separated from wastes can range from those using only hand labor to fully automated mechanical separation processes. The unwanted fish parts become part of the waste stream that the processor must manage. General waste management and by-product recovery practices are reviewed in Section 4.
The North American Industry Classification System (NAICS) divides the seafood processing industry into two main categories: Seafood Canning (NAICS code 311711), defined as "establishments primarily engaged in (1) canning seafood (including soup) and marine fats and oils and/or (2) smoking, salting, and drying seafood"; and Fresh and Frozen Seafood Processing (NAICS code 311712), defined as, "establishments primarily engaged in one or more of the following: (1) eviscerating fresh fish by removing heads, fins, scales, bones, and entrails; (2) shucking and packing fresh shellfish; (3) manufacturing frozen seafood; and (4) processing fresh and frozen marine fats and oils" (U.S. Census Bureau, 2010, 2010a). The non-remote Alaska seafood processing facilities are represented within both of these NAICS categories.
Significance of the Alaska Fisheries and Seafood Processing Industry in the Global, U.S., and Regional Economies
Fisheries
The Alaska seafood processing industry is an important part of the U.S. industry, and a minor, but measurable, contributor to the global industry. The inputs to this industry; fish, shellfish, and other seafood in terms of production volumes, are an indicator of the seafood processing industry's importance in Alaska, that region, the United States and the world. In 2008, global fish production (which combines aquaculture and commercial catch [landings]) was more than 142 million metric tons of fish, with commercial landings estimated at nearly 90 million metric tons (NMFS, 2010) (see Table 1). In that year, the United States was the fifth largest seafood producer in the world with roughly four million tons of fish produced. Landed seafood is the biggest contributor to U.S. seafood production. Aquaculture makes up the rest of seafood production, contributing less than 10 percent to total production.
The top fish-producing region in the United States was, and continues to be, the Pacific Coast region, which includes the states of Alaska, Washington, Oregon, and California. In 2008, the region landed 2.6 million metric tons of seafood, which is about 67 percent of all U.S. landings and more than four times the landings of the second largest fish producing region, the Gulf Coast, which landed 0.6 million metric tons of seafood (throughout the remainder of the document, "tons" are considered to be metric tons, unless otherwise noted). The region's landings also make up one half of the total value of U.S. landings.
Table 1. 2008 Fish Production and Processing Overview
Location/Scale
Commercial Fish Landings
(million tons)
Percent of U.S. Landings
Value of Commercial Fish Landings
($ billions)
Percent of U.S. Value of Landings
World
89.74
NA
NA
NA
United States
3.78
--
$4.4
--
Pacific Coast Region
2.55
67%
$2.2
50%
Alaska
2.06
54%
$1.7
39%
Source: NMFS, 2010.
Alaska is by far the largest contributor to total seafood production in the Pacific Coast Region and in the United States. During the time period 1997-2007, Alaska accounted for 51 percent of the nation's total landings, by weight, of fish and shellfish (Bimbo, 2008).  The state's landings of 2.06 million tons in 2008 were approximately 81 percent of total Pacific Coast seafood landings, 54 percent of all U.S. landings, and about 1 percent of global fish production in that year (NMFS, 2010). (Fish landings comprise nearly all of Alaska fish production, since aquaculture plays little role in the state's fishing economy.) In 2008, Alaska led all states in the amount of fish landings. The next largest contributor to landings was Louisiana, with approximately 0.4 million tons. Alaska also led in the value of those landings ($1.7 billion) (NMFS, 2010). This is 77 percent of the value of landings produced by the Pacific Coast Region and about 39 percent of the value of landings in the United States (see Figure 1). The value of landings per ton of fish landed, however, lags behind the average for the United States, possibly reflecting the cost of transportation to the major lower 48 and Asian markets.
Figure 1. Alaska Fish Production as it Relates to Regional and National Production
National Marine Fisheries Service, 2010.
 Seafood Processing
Much of the fish landed in the United States and abroad undergoes a processing step prior to being marketed. More than half of the world's fish production (54%) underwent some form of seafood processing in 2006 (FAO, 2008).  In the United States, the primary form of processing for human consumption in 2009 was fresh and frozen (77%), followed by canning (15%), and curing (2%). For non-human consumption, the primary products were bait and animal food (3%) as well as meal and oil (3%) (NMFS, 2010).
As of 2007, seafood processing plants numbered 652 across the United States and employed about 39,000 workers (U.S. Census Bureau, 2007a) (see Table 2). The Pacific Coast region, which includes the state of Alaska, is home to 282 seafood processors (or 43 percent of total U.S. seafood processing establishments). This region also is associated with more than half the U.S. employment and receipts. Nearly half of the establishments located in the Pacific Coast region, 116 facilities, are located in Alaska. These 116 facilities make up nearly 20 percent of the total U.S. seafood establishments (U.S. Census Bureau, 2007a, b). Alaska employs nearly 9,000 workers, or about 23 percent of the U.S. total for the industry. Total receipts in Alaska are $2.2 billion, also about 20 percent of total receipts in this industry throughout the United States. The fact that Alaska by itself makes up so much of the seafood processing industry in the United States is notable.
Table 2. Alaska Seafood Processing in the Context of Its Region and the U.S. Seafood Processing Industry
GEOGRAPHIC AREA
NO. OF ESTABLISHMENTS
% OF U.S. ESTABLISHMENTS
NUMBER OF EMPLOYEES
% OF U.S. EMPLOYEES
TOTAL RECEIPTS
($ BILLIONS)
% OF U.S. RECEIPTS
Alaska
116
18%
8,870
23%
$2.2
20%
Fresh and frozen
98
18%
7,934
22%
$2.0
20%
Canning
18
19%
936
33%
$0.2
20%
Pacific Coast
282
43%
21,445
55%
$5.9
53%
Fresh and frozen
237
42%
18,687
52%
$4.9
49%
Canning
45
48%
1,689
60%
$0.7
70%
United States
652

38,968

$11.1

Fresh and frozen
558

36137

$10.0

Canning
94

2,831

$1.0

Source: U.S. Census Bureau, 2007a, b. Does not include non-employer establishments (33 non-employer establishments are located in Alaska and more than 217 in the Pacific Coast region).
The seafood processing industry in Alaska has changed somewhat in the last decade.  In 1997, there were 31 canning establishments (average March employment per establishment was 40) and 91 fresh and frozen establishments (average March employment of 65) in Alaska, according to the Census. The canning industry in 2007 consisted of 18 establishments (average employment 52) and 98 fresh and frozen establishments (average employment 81). Thus, the number of canning establishments in Alaska has decreased substantially during the recent decade, with production being concentrated in fewer, larger facilities. Meanwhile, the number of fresh and frozen establishments has grown somewhat since 1997, while the size of those establishments, on average, has become larger (based on average employment). Thus, overall, the number of seafood processing establishments has declined only slightly, but the process has shifted from canning to fresh and frozen and the establishments themselves have become larger over the years (U.S. Census Bureau, 2007a; 2000a).
Overview of the Seafood Processing Industry in Alaska
Alaska's 116 seafood processing plants are divided by EPA definitions into direct discharging, indirect discharging (discharging to publicly owned treatment works), or non-discharging. The facilities are also classified as operating in remote or non-remote processing locations for regulatory purposes. At this time, 21 facilities are designated as operating in non-remote locations (that is, they are located in or near the cities of Anchorage, Cordova, Juneau, Ketchikan, Kodiak, and Petersburg). However, some of these facilities are currently discharging wastes to publicly owned treatment works and, therefore, are not subject to the BPT requirements for direct dischargers, the focus of EPA's potential actions. Several others (six establishments) are located in Kodiak and currently are meeting the requirements for non-remote processors. EPA considers a total of 14 facilities with direct discharge to be potentially affected by its decision on the petition and a possible final regulation as discussed in Section 1. The remaining establishments operating in Alaska have been considered as being remote land-based, nearshore, or offshore establishments. The 116 seafood processing facilities are owned by an estimated 86 employer firms (U.S. Census Bureau, 2007b). This number includes more establishments than considered by EPA in the ELG, including floating processors, those which have primarily retail operations or some other business with seafood processing as a small portion of the business, and those which have ceased operations. At the national level, approximately 96 percent of firms owning seafood processing establishments are small businesses as defined by the Small Business Administration (SBA), employing on a yearly average fewer than 500 employees (Federal Register, 2010). Known large firms owning processing facilities in Alaska include Trident Seafoods, Icicle Seafoods, Ocean Beauty Seafoods, and the Japanese firms Maruha Nichiro Holdings, Nippon Suison Kaisha, and Marubeni.  Additional information on these firms is presented in Section 3.1.2.  A total of six small businesses are estimated to be affected by EPA's decision on the petition. Section 3.2 discusses how small businesses were identified in these groups of firms.
The Major Alaskan Fisheries and their impact on Seafood Processing Finances
The seafood processors in Alaska are dependent on their fisheries, which drive the economics of the industry. Alaska has five major fisheries, which harvest and process particular species of fish. Alaska's major fisheries include: 1) salmon (such as coho, sockeye, and chum), 2) halibut, 3) herring, 4) shellfish (such as king crabs and tanner crabs), and 5) groundfish (such as pollock, rockfish, flounder, haddock and cod) (Knapp, 2010). Each fishery is managed by the Alaska Department of Fish and Game (ADFG) with the exception of halibut, which is managed by the International Pacific Halibut Commission (IPHC). The volume of seafood production each fishery contributes to the Alaskan fishing and manufacturing industry has varied widely over time. For example, a shellfish boom between 1960 and 1980 turned Kodiak into Alaska's "crab capital," during which time the king crab catch in Alaska totaled about 110,000 million tons, much of it landed in Kodiak. Beginning around 1980, the king crab catch declined dramatically, decreasing by more than 100,000 million tons by 2002 (Knapp, 2010). With king crab harvests slow to recover, harvesters have focused more on tanner and snow crab, and the Bering Sea, Aleutian Island, and Gulf of Alaska region is now the center of crab production in the state (ADFG, 2009).  Dutch Harbor production is now dominated by pollock.
The Alaskan groundfish fishery also has a history of fluctuating volumes and harvesters. Prior to 1972, groundfish production was flourishing under foreign harvesters who began targeting the pollock fishery. With little regulation of gear or rules to prevent overfishing, contention was high among large, foreign factory boats and the smaller domestic pot fisheries and longliners. As groundfish production sharply declined after 1972, the United States established the U.S. Exclusive Economic Zone (EEZ), which created a 200-mile conservation zone. To promote U.S. fisheries, the U.S. government put forth various policies, following creation of the EEZ, such as the American Fisheries Promotion Act. These policies obligated foreign harvesters to meet many more requirements in order to fish within the EEZ (such as the purchasing of U.S. fisheries products and technology transfer relating to fishing and boating equipment). In combination with incentive programs such as the NMFS Fisheries Obligation Guarantee Program, which provided loans for U.S. factory trawlers and processors in order to facilitate industry growth, these strategies shifted the once foreign-based groundfish fishery into domestic hands by the early 1990s (Bechtel, 2010).
Several factors shape the financial standing of the Alaskan seafood processing industry each year. On a broad level, financial fluctuations may occur due to consumers' changing seafood product preferences or the quantity of seafood available to meet those consumer demands. For instance, the ex- vessel price for herring decreased by more than 70 percent from1995 to 2003 because Japan, one of the main markets for Alaskan herring products, dramatically decreased its purchases of luxury herring products as its economy stagnated (Knapp, 2007). Seafood availability, which can fluctuate by up to 50 percent each year, can be shaped by factors such as fish productivity cycles that can be sensitive to seasonal temperatures, spawning patterns, or species health, as discussed above (Knapp, 2010).
The economic crisis experienced by the Alaskan salmon industry in the 1990s provides one example of the potential financial impacts resulting from fluctuations in seafood availability. During the 1990's the farmed salmon industry emerged and created a high degree of competition with Alaskan salmon.[.]  Atlantic salmon farmed in Norway, Chile, Scotland, Canada (both British Columbia and eastern Canada), and Maine greatly increased the volume of salmon production. As a result of the increased supply from the salmon farms, the price paid to fishermen dropped from $2 per lb to less than $1.00 per lb for most species of salmon except Chinook (Knapp, 2010).
Figure 2 shows the ex-vessel price for the volume of Alaska's fishery landings in 2008. The ex-vessel price is the price that the processor pays for the seafood when the product leaves the boat. The figure illustrates the relative value of each fishery to Alaska's economy in 2008 before any processing or value-added procedures are undertaken. For example, although nearly twice as many tons of herring were landed as halibut, the ex-vessel value of halibut landings was almost $150 million greater than that of the herring (ADFG, 2008).

Figure 2. 2008 Fish Landings and Ex-Vessel Values by Alaska Fishery
Source: Alaska Department of Fish and Game, 2010; International Pacific Halibut Commission (IPHC, 2010). Halibut Ex-vessel Price was calculated by using ADFG average ex-vessel price for all Alaskan locations.
Source: ADFG, 2008.
At the processor level, the fish price negotiated between harvesters and processors can be a critical financial factor. In Alaska, seafood processors operate independently from harvesters. The pollock fishery is the exception; it operates primarily from large, offshore processing vessels. As a result, processors can purchase their seafood from anyone, but the fishermen can also sell their catch to anyone, subject to contractual or other agreements. Although processors and harvesters rely on each other in order to generate income from their businesses, part of their financial success depends on the fish prices negotiated between the two parties each season. Processors can be very competitive for access to fish, and the level of competition fluctuates depending on the number of processing plants in the vicinity, the strength of the overall market as well as the value of the fish. For example, during years in which fish quantities are limited, competition between processors may increase, and processors, therefore, may be willing to pay a higher price for fish than in years where is an ample supply of fish. In years in which fish are abundant, processors may limit the number of fish they are willing to purchase from a harvester. Land-based processors must also keep in mind, however, the possibility for floating processors to move into an area during good fish-producing seasons, potentially decreasing the volume of fish brought to land-based processors (Knapp, 2010).Because of the uncertainty of the purchasing and processing arrangement, fishermen and processors will often make an agreement for the fishing season or year. For example, a fisherman might agree to limit the processor's supply to the quantity of fish that the processor is able to use. In return, the processor agrees to pay the fisherman a certain minimum price. Additionally, fishermen may seek loans from processors for new fishing vessels and enter into a contractual agreement with the processor that requires a specified percentage of the catch to be provided to that processor. Harvester-processor agreements are sometimes broken by both parties, and suspicions of collusion among processors often arise among harvesters. The mobility of the both the producers (harvesters) and, in some cases, the consumers (the processors) can result in a highly competitive environment for an often limited resource. The competition for fish, the volatility of supply, and the resulting effects on revenues mean that the financial picture at seafood processing establishments can vary widely from year to year (Knapp, 2010).
Beyond the ex-vessel price, processors also pay a range of taxes. These taxes might include a landing tax[,] fish business tax, or raw fish tax. For example, seafood processors pay a fisheries business tax "based on the price paid to the fishermen for the unprocessed fisheries resource" and the value paid depends on the species of fish (ranging from 1 to 5%) as well as the type of processing that will be undertaken (Alaska Department of Revenue, 2010). The state returns half of the collected tax to the community in which the processor is located. Some communities use the fisheries tax revenues for activities related to fishing and seafood processing, while others use the tax revenues in their general funds for the town (roads, schools, library, etc.) (Alaska Department of Commerce, Community, and Economic Development (DCCED), 2010).
Alaska Seafood Processing Facilities and Firms in the Petitioning Non-Remote Processing Locations and Additional Remote Processing Locations of Interest
This section discusses the firms and facilities in several smaller areas of Alaska or "seafood processing locations" which could be affected by EPA's final amended regulations.  The primary focus of this section is the 14 facilities in the non-remote processing locations that are considered by EPA to be "petitioning locations" (see Section 3.1 for the identification of these facilities). As noted, these petitioning locations include Anchorage, Cordova, Juneau, Ketchikan, and Petersburg. While Kodiak is a non-remote location, it is not a petitioning location, and no direct discharge is occurring in Anchorage at this time. Neither of these locations is discussed further in this report. This section also presents profile information on two additional locations currently classified as remote that EPA's 1981 proposal solicited comment on considering including as non-remote locations (Dutch Harbor and the Kenai Peninsula) plus one additional location identified during this update and (Sitka), and which are associated with 16 facilities. These are considered the remote locations of interest. Other possible additional locations are not discussed in any detail. Finally, no nearshore, offshore processing, or floating processors are profiled, because these facilities were not covered by the original effluent limitations guidelines and thus are not within EPA's focus at this time. However, with the growth of floating processors in Alaskan waters, since the mid-1980s the ELGs also have been applied to many of these floating processors in a general permit as necessary and appropriate. Information collected by EPA from nearshore and offshore floating processors has provided helpful contextual information to assist in better understanding land-based processing operations in comparison to the rest of the industry in Alaska. Figure 3 shows the State of Alaska with the petitioning locations and the other locations of interest located on the map. With the exception of Dutch Harbor, salmon represents the vast majority (more than 90%) of the seafood processed in each of the processing locations discussed in this section.
Figure 3. Map of ADFG Harvest Areas with Seafood Processor Locations

Source: Map with harvest areas taken from ADFG, 2010. Processing locations added by EPA.

Section 3.1 presents an overview of the direct discharging facilities (both petitioners and those in the locations of interest). The section first discusses the facilities in the non-remote processing locations involved in the petition (Section 3.1.1) and then discusses the facilities in several remote locations of interest that EPA is considering to determine whether they now have attributes similar to non-remote locations (Section 3.1.2).  Section 3.2 then presents an overview of the owner firms of the direct discharging facilities, first in the petitioning locations (Section 3.2.1), then in the remote locations of interest (Section 3.2.2).
Overview Of Facilities and Firms
This section describes the land-based seafood processing facilities and firms holding effluent discharge permits in the non-remote, petitioning processing locations (Section 3.1.1) and remote locations of interest (Section 3.1.2). Table 3 summarizes basic information on the facilities in these two groups of locations.
Petitioning Non-Remote Processing Location Facilities
This section provides brief summaries of the facilities that are currently located in the non-remote processing locations that petitioned EPA (see Section 1).  Sources for this information are primarily corporate websites unless otherwise cited.  Fourteen distinct discharging facilities are located in the petitioning locations, of which EPA surveyed 11 facilities from data received for the nine entities which received information collection requests. The three facilities not surveyed are identified in their descriptions, which are presented below. The information submitted by the respondents to the survey included both technical and financial data to support analyses of costs and impacts associated with meeting the requirements for non-remote seafood processing discharges as described in Section 1. EPA reviewed the financial information submitted for the 11 facilities.  All of these facilities are considered financially viable as of 2009. Additional financial details from the survey, however, are considered Confidential Business Information (CBI) and are not provided here. See Report to the Record Cost and Economic Impact Analysis for Alaska Seafood Processors (Facilities and Firms) 2013, DCN XXXXX.
Cordova
Cordova is the most northerly located petitioning location currently practicing direct discharge. It is located relatively near Anchorage and the Kenai Peninsula (see Figure 3). Four direct discharging facilities in Cordova process seafood.  One is owned by a small, independent firm, Copper River Seafoods, which also has a facility in Anchorage that does not discharge directly.  The other three are facilities owned by large firms that operate nationally, as well as in Alaska (Copper River, 2010; Ocean Beauty, 2010b; Trident Seafoods Corporation, 2010g).
Copper River Seafoods -- In 1996, Copper River Seafoods took ownership of a 70-year old processing plant in Cordova where it now processes fresh, frozen and smoked seafood products using a variety of salmon, halibut, cod, and rockfish. The Cordova plant also processes salmon roe into ikura and sujiko.  Fresh fish, predominantly salmon, is shipped to Anchorage. Frozen fish is exported. Copper River Seafoods' Cordova plant operates from May 15 through September 15 and employs a portion of the company's 150 seasonal employees.
Ocean Beauty -- The Ocean Beauty Cordova plant operates February through September. The plant processes halibut, black cod, rockfish, and salmon. It is one of the largest producers of Copper River King and Sockeye salmon in Alaska.
Norquest Seafoods (Trident South) -- The Norquest Seafoods (Trident South) plant is owned and operated by Trident Seafood Corporation, which took ownership in 2007. The facility operates March through September and processes a variety of bottom fish, sable fish, halibut, and salmon. Salmon and halibut comprise the majority of the facility's finished product.
Trident Seafood Cannery (Trident North) -- Formerly owned by Bear and Wolf, the Trident Seafood cannery processes salmon from May through early September. In 2008, the plant produced more than 20 million lbs of canned salmon.

Table 3.  Facility Overview by Petitioning Locations and Locations of Interest
Facility
(By location)
Owner Firm or Parent
Employment
Type of Products
Type(s) of Seafood Used
Facilities in Petitioning Locations
Cordova
Copper River Seafoods−Cordova
Copper River Seafoods
150
Fresh ,frozen, smoked, and roe
Salmon, halibut, cod
Ocean Beauty−Cordova
Ocean Beauty Seafoods
NA
NA
Halibut, black cod, rockfish, and salmon
Norquest Seafoods
Trident Seafood Corporation
NA
NA
Bottom fish, sable fish, halibut, and salmon
Trident Seafood Cannery
Trident Seafood Corporation
NA
Canned
Salmon
Juneau
Alaska Glacier Seafoods
Alaska Glacier Seafoods
70
Fresh and Frozen (whole and fillet), roe
Chum salmon, black cod , halibut, rockfish, crab, spot prawns, sea cucumbers, various ground fish
Taku Fisheries
Alaska Seafood Holdings (parent)
NA
Fresh, frozen, and smoked
Salmon, halibut, black cod
Ketchikan
Alaska General
Alaska General
NA
Canned,
Fresh and frozen , roe
Salmon
E.C. Phillips and Son, Inc
E.C. Phillips and Son, Inc.
NA
Fresh and Frozen
Salmon, halibut, rockfish, shrimp, cod, herring, sea cucumber and geoduck
Pacific Sun Products
Coastal Fisheries, LLC
NA
Fresh, frozen, and canned
Salmon
Ketchikan Cannery
Trident Seafood Corporation
NA
Canned and roe
Salmon
Trident Seafoods
Trident Seafood Corporation
NA
Fresh and Frozen
Salmon, sea cucumbers, prawns, and crab
Petersburg
Icicle Seafoods
Icicle Seafoods, Inc. (Paine & Partners, parent)
500
Fresh/frozen, canned, and value-added products
Salmon, halibut, cod, crab (various species)
Ocean Beauty−Petersburg
Ocean Beauty Seafoods
160-180
Ikura, Fresh/frozen and canned
Salmon
Trident Seafoods −Petersburg
Trident Seafood Corporation
NA
NA
Salmon, halibut, black cod, and rockfish
Non-Petitioning Facilities in Locations of Interest
Dutch Harbor
Alyeska Seafoods
Maruha Nichiro Holdings (parent)
NA
Fresh and frozen
Crab
Bering Star Fisheries, LLC *
Copper River Seafoods and Siu Alaska (Norton Sound Economic Development Corporation)
NA
NA
NA
UniSea
Nippon Suison Kaisha (parent)
450-950
Surimi, fresh, and frozen
Cod, halibut, pollock, snow and king crab
Westward
Maruha Nichiro Holdings (parent)
220
NA
Pollock, cod, halibut, and crab
Kenai Peninsula
Inlet Fish Producers Kenai
Inlet Fish Producers
200 (total for both facilities)
Fresh and frozen
Salmon and halibut
Inlet Fish Producers Kasilof
Inlet Fish Producers
NA
Fresh and frozen
Salmon and halibut
Ocean Beauty−Nikiski
Ocean Beauty Seafoods
NA
Fresh and frozen
Salmon
Pacific Star Seafoods
Double E Seafoods, LLC
NA
Fresh/frozen and smoked products
Salmon, sablefish, halibut, cod, and rockfish
Salamantof Seafoods
Salamantof Seafoods
NA
NA
Cod, rockfish, halibut, and salmon
Snug Harbor Seafoods
Snug Harbor Seafoods
200
Fresh, frozen, and smoked
Sablefish, rockfish, cod, halibut, and salmon
Icicle Seafoods
Icicle Seafoods, Inc. (Paine & Partners, parent)
300
Fresh/frozen, canned
Black cod, halibut, and salmon
Polar Seafoods
Polar Equipment
NA
NA
Salmon and groundfish
Resurrection Bay Seafoods (Sea Level Seafoods)
Pacific Seafoods (parent)
NA
NA
Cod, rockfish, sablefish, and halibut
The Fish Factory (City of Homer permit)
The Fish Factory
20-49
Fresh and frozen
NA
Sitka
Silver Bay Seafoods [a]
Silver Bay Seafoods
200
Fresh, frozen, and roe
Salmon, halibut, crab, and herring
North Pacific Seafoods (Sitka Sound Seafoods)
Marubeni Corporation
220 (North Pacific)
NA
Salmon, halibut, sablefish, rockfish, herring, sea cucumbers, cod, shrimp and Dungeness crab
Seafood Producers Cooperative
Seafood Producers Cooperative
NA
Fresh, frozen, roe, and bait
Salmon, halibut, bottom fish, sablefish and herring
Source:  Where not cited, information is from corporate websites (see footnote 9).
Note: NA represents information that is not publically available.
[a] The City/Borough of Sitka is the NPDES permit holder for the outfall used primarily by Silver Bay Seafoods.

Juneau
Juneau is located on the mainland of Alaska in the area known as the Inside Passage of the Alexander Archipelago, which is where most of the discharging petitioning location facilities are located (see Figure 3).  Juneau is home to two small direct discharging seafood processors.
Alaska Glacier Seafoods -- The Alaska Glacier Seafood (AGS) plant is located on Auke Bay, about 13 miles north of downtown Juneau. The plant is five years old and processes small volumes of a wide variety of seafood such as fresh and frozen salmon and crab along with cod, sea cucumbers, halibut, shrimp and prawns. Nearly 80 percent of production goes into making fillets, while the remainder of production is whole fish. AGS operates March through November and processes approximately seven million pounds of seafood a year. The facility employs 70 people during the peak season.
Taku Fisheries  -- The Taku Fisheries plant is located in downtown Juneau, immediately adjacent to the cruise ship docking area and the Mount Roberts tramway. It was built in 1994 and has a footprint of 44,000 square feet. Taku operates a retail store, mail/Internet sales, as well as wholesale. Taku and Icy Strait Seafoods, the latter of which is located in Washington State, are sister companies and wholly owned subsidiaries of Alaska Seafood Holdings, Inc. Taku Fisheries produces a variety of frozen, smoked, and value-added salmon products. The plant operates 10 months per year, processing an average of seven million pounds of seafood annually. About 60 to 70 percent of production is salmon (usually higher value fish such as sockeye and king and little pink). Taku also processes halibut, black cod, rockfish, and crab (king, tanner, and Dungeness). Most of the production is whole fish (headed and gutted), frozen and barged out to Seattle. In 2010, Taku employed 40 foreign student workers in the United States on J-1 visas as well as 30 workers residing in Juneau. This facility and its firm were not surveyed by EPA.
Ketchikan
Ketchikan, also located in the Alexander Archipelago/Inside Passage region, is at the southern entrance of the Inside Passage (see Figure 3). It is the location of the largest number of direct discharging facilities in the petitioning locations. Five discharging facilities operate here, two of which are owned by Trident.
Alaska General -- Alaska General's Ketchikan plant began operating in Ketchikan in 1906 as the New England Fish Company and was later purchased and operated by the Canadian Fishing Company in 1990 under the name of Kanaway Seafoods. The current company, Alaska General Seafoods, was established in 1999 after the assets from Kanaway Seafoods, Nelbro Packing Co. and Alaska General Processors were combined to form Alaska General Seafoods. Today, the plant operates on a seasonal basis from June through mid September. AGS takes the plant out of winter storage in April. Salmon canning operations begin in the 4th week of June and last until the end of August. The plant produces fresh, frozen, and canned salmon and herring products. About 85 percent of their production is canned pink salmon; the remainder is fresh and frozen salmon - pink and other species. This facility and its firm were not surveyed by EPA.
E.C. Phillips and Son, Inc. -- E.C. Phillips has operated in Ketchikan since 1926 (almost 85 years).The E.C. Phillips facility processes a variety of fresh and frozen seafood including salmon, halibut, ling cod, geoduck, spot shrimp, herring, and sea cucumbers. The plant was built in 1950 and operates year round. When salmon season ends in October, the plant begins processing dive fish (sea cucumbers and geoduck) and continues to process salmon that was frozen in the summer months into portions and fillets. The final products from this facility are packaged into boxes and transported in shipping containers all over the world.  Fish are sold fresh and frozen, whole with head on, headed and gutted, filleted and portioned. The company employs between 200 to 250 workers, with approximately 190 positions attributed to summer processing. A seasonal employee may work 450 to 600 hours in the four-month season.
Pacific Sun Products -- Owned by Coastal Fisheries, LLC, Pacific Sun Products produces fresh, frozen, cured and canned seafood products. The entire variety of fish produced by the facility is not publically available but previously has included salmon and sea urchin roe. This facility and its firm were not surveyed by EPA.
Trident Seafoods (Norquest) -- One of two plants that Trident owns in Ketchikan, this plant was owned by Norquest Seafoods until 2006. The plant produces primarily salmon, but it also processes a variety of other species such as halibut, geoduck, and cod. Unlike many of the other facilities in the petitioning locations, this facility is open year-round.
Trident Seafoods, Ketchikan Cannery -- This facility primarily processes canned salmon, but it does process sea cucumbers, prawns, and crab as well. The facility operates from June through October.
Petersburg
Petersburg is located on Mitkof Island, within the Alexander Archipelago's Inside Passage, roughly between Ketchikan and Juneau, but across one arm of the Passage from these locations (see Figure 3). Three facilities regularly operate in Petersburg, all owned by large firms.
Icicle Seafoods -- The Petersburg Icicle plant is the oldest seafood processing facility in Alaska. The plant operates February through November, processing salmon, pollock, halibut, cod, and a variety of crab. The facility processes fresh, frozen, canned, and value-added products such as surimi. Most halibut is sold fresh, and all cod is frozen. Halibut heads are used for bait with 100 percent product utilization. The plant also processes a special form of spring herring roe (roe on kelp), which is frozen and shipped to Japan.
Ocean Beauty -- The Ocean Beauty Petersburg facility operates from April to mid-September, seasonally employing between 160 and 180 workers. The facility produces ikura as well as fresh, frozen, and canned salmon. This plant closed temporarily in 2010 (Trident, 2010b).
Trident Seafoods (Norquest) -- Previously owned by Norquest Seafoods, the Trident Petersburg facility processes salmon, halibut, black cod, and rockfish. The plant processes seafood from March through November. The Trident Mitkof plant, which was also previously owned by Norquest Seafoods, is associated with this plant. The facility was not operational in 2008, although in 2007, it processed salmon during the months of July and August. EPA is not analyzing this facility.
Processing Locations of Interest Currently Classified as Remote
This section provides an overview of the facilities that are located within areas currently designated as remote processing areas but that have a number of processors within geographical proximity of one another. Six of these facilities and their firms were surveyed. EPA reviewed the financial information for those surveyed facilities located on the Kenai Peninsula; the facilities surveyed in this location are considered financially viable as of 2009.  Additional financial details are not provided here because of confidential business information considerations. The facilities in these locations that were surveyed are identified in their descriptions presented below. The facility descriptions below are based on information found on corporate websites unless otherwise cited.
Dutch Harbor
Dutch Harbor is remote by geographic standards, being located midway along the Aleutian Islands chain (see Figure 3). It is the port of Unalaska, one of Alaska's larger cities. This harbor is one of the most active and largest (by production) fishing and seafood processing locations in Alaska (NMFS, 2010). There are three existing shore based processors in this location and one that is expected to be operational this year. The three existing facilities are all owned by Japanese firms.
Alyeska Seafoods -- Alyeska Seafoods processes fresh and frozen crab in its Dutch Harbor facility. Other facility-level information is not made publically available. This facility, its firm, and its parent company were surveyed by EPA.
Bering Star Fisheries, LLC -- In August 2010, Copper River Seafoods and Siu Alaska Corporation announced that Bering Star Fisheries will be operating the Harbor Crown floating (barge) processing plant in Dutch Harbor beginning January 2011. Bering Star Fisheries was formed by the Dutch Harbor Acquisition LLC, a company comprised of Copper River Seafoods through Western Alaska Ventures LLC, one of its partners, and Siu Alaska Corporation, a wholly-owned subsidiary of the Norton Sound Economic Development Corporation. The plant will be processing cod, halibut, and crab out of the previous Harbor Crown plant beginning in January 2011. Employee and revenue estimates are not yet available given that it is a start-up facility.
Westward -- This Dutch Harbor facility produces 254 million lbs of seafood annually. It is a sister facility to Alyeska Seafoods, with the same Japanese firm as its ultimate parent firm. Although the facility focuses on Alaskan pollock, it also processes cod, halibut, and a variety of crab (Westward, 2010a). A total of 220 employees are considered to work at this location (Manta, 2011b).  This facility, its firm, and its parent company were surveyed.
UniSea -- UniSea processes cod, halibut, pollock, snow and king crab, and surimi as well as white fishmeal and fish oil in its Dutch Harbor facility. The fishing season begins around January for crab, pollock, and cod and runs through mid-November. The automated processing facility has the capability of processing 60 metric tons of seafood per hour. Information on how many of the company's estimated 600 to 1200 workers are employed at this facility is not available.
Kenai Peninsula
EPA has grouped Seward, in the northeastern portion of the Kenai Peninsula, with more southerly and westerly areas near the cities of Kenai, Nikiski, and Homer, AK, to define the Kenai Peninsula processing center (see Figure 3).  The ten discharging facilities that operate in this area are mostly relatively small.  A few facilities initially identified as permitted dischargers have since been determined to no longer discharge regulated wastewater. Kenai Landing (Scientific Fisheries) is, at this time, operating only as a by-product recovery plant, and Deep Creek does not believe it will be subject to discharge permits going forward (Deep Creek Custom Packing, 2011). These two facilities are not discussed further in this report.
Icicle Seafoods -- The Seward Icicle facility processes black cod, halibut, and salmon into fresh, frozen, and canned seafood products. The plant also produces fishmeal. The season for cod and halibut runs from March 8th through November 15th, and the salmon season runs from June through the end of August. During salmon season, employment may reach 300 workers. This facility and its firm were surveyed.
Inlet Fish Producers (Kenai) -- Inlet Fish Producers Kenai facility operates from June through early September with the peak season from early July until mid-August. Approximately 250 seasonal workers are hired to work in the plant to unload, butcher, and freeze the fish (combined with the Kasilof facility employment). This facility and its firm were surveyed.
Inlet Fish Producers (Kasilof) -- Inlet Fish Producers (Kasilof) operates from June through early September, with the peak season from early July until mid-August. The seasonal workers (counted with the Kenai plant employment) are hired to work in the plant to unload, butcher, and freeze the fish. This facility and its firm were surveyed.
   * Ocean Beauty -- Ocean Beauty's Nikiski plant processes frozen (and some fresh) coho, chum, pink, sockeye, king salmon, salmon roe, halibut and cod during a season that generally runs from the beginning of April through the end of October. This facility and its firm were surveyed.

Pacific Star Seafoods -- Pacific Star processes salmon, sablefish, halibut, cod, and rockfish from more than 50 independent fishermen to produce fresh, frozen, and smoked products. The facility, which is owned by Double E Seafoods, operates from May through August.
Polar Seafoods -- The Polar Seafoods facility, owned by Polar Equipment, processes fresh and frozen seafood. The facility processes groundfish from January through April and salmon from July through September.
Salamatof Seafoods -- Salamatof Seafoods is affiliated with the Salamatof Native Association, Inc. The facility processes cod, rockfish, halibut, and salmon.
Sea Level Seafoods (Resurrection Bay Seafoods) -- The Seward Resurrection Bay facility is owned by Sea Level Seafoods, which is based in Wrangell and is doing business as Resurrection Bay Seafoods. The parent company is Pacific Seafood Company. The facility processes cod, rockfish, sablefish, and halibut from March through mid-November.
   * Snug Harbor -- The Snug Harbor processing facility produces fresh, frozen, and smoked seafood products from sablefish, rockfish, cod, halibut, and salmon. The facility process seafood from March through November or until fish quantities are depleted for the season. Snug Harbor employs approximately 200 seasonal workers. This facility and its firm were surveyed.
The Fish Factory -- The Fish Factory processes fresh and frozen fish at its facility in Homer, Alaska. The company is estimated to employ approximately 20 to 49 workers, but public information does not specify whether these workers are all employed at the processing facility. Public information also does not mention types of fish or other processing particulars for this facility. The facility uses the City of Homer fish grinding facility that is owned and managed by the port and Harbor of Homer. The NPDES permit holder for the wastewater discharges is the City of Homer. The facility grinds and discharges fish waste from charter operations, sports fisherman, and The Fish Factory and operates from January through November.
Sitka
Sitka is located on Baranof and Chichagof Islands on the western side of the Alexander Archipelago, about 100 miles from Petersburg, AK (see Figure 3). Of the four discharging facilities EPA initially identified, Absolute Fresh Seafoods appears to be out of business (it did not file discharge reports for 2005 through 2010 with either ADEC or EPA Region 10) and will not be discussed further in this report.
North Pacific Seafoods -- The North Pacific Seafood processing plant in Sitka, also known as Sitka Sounds Seafoods, "processes all species of salmon from all gear types, halibut, sablefish, rockfish, herring, sea cucumbers, lingcod, Pacific cod, shrimp and Dungeness crab" (North Pacific Seafoods, 2010a). Processing occurs from March to the end of October, with the major salmon season occurring from mid-June through September. The facility employs 220 workers during the peak season.
Seafood Producers Cooperative -- The Seafood Producers Cooperative plant operates year- round. The facility processes salmon, halibut, bottom fish, sablefish as well as herring bait and roe.
Silver Bay Seafoods -- Silver Bay Seafoods is the largest seafood processing facility in Sitka, and one of the larger facilities among the discharging facilities in either the locations of interest or the petitioning locations. The facility discharges under a permit held by The City/Borough of Sitka through an outfall located on Saw Mill Road. Silver Bay is currently the primary processor using this outfall as of 2009. During 2007 and 2008, Silver Bay jointly discharged through this outfall with Baranof Frozen Foods, which is no longer operating. The full variety of seafood processed by Silver Bay Seafoods is unknown, although it does include salmon.  During the 2010 salmon season, 200 seasonal workers were employed for fish processing and facility maintenance.
Firms Owning Facilities in the Petitioning Non-Remote Processing Locations and Remote Locations of Interest
This section presents information on the firms that own facilities in the petitioning locations (Section 3.2.1) and the additional firms that own facilities in the locations of interest (Icicle Seafoods and Ocean Beauty Seafoods own facilities in both petitioning locations and locations of interest) (Section 3.2.1). Table 4 presents the firms with Alaskan processors discussed in these two subsections (those firms for which the facility information is all that is available, are not repeated here). The table is divided by firms of direct discharging processors in the petitioning locations and the firms with direct discharging processors in the remote locations of interest.  Most employment and revenue figures are estimates made by firms that specialize in providing this information; some estimates may be better than others. For the purposes of this profile, these estimates are considered approximate only. As the table shows, among the potentially affected petitioners, three firms have been identified as small, three firms have been identified as large, and three firms could not be identified by size and are presumed small. Among those in the locations of interest, five are identified as small, four are identified as large, and three could not be identified by size and are presumed small.
Table 4. Firms with Potentially Affected Petitioning Alaskan Processing Facilities and Those with Facilities in the Locations of Interest
Firm
Headquarters Location
Facility Locations
Large or Small Firm
Employment
Annual Revenue
($ millions)
Firms in Petitioning Locations
Alaska General Seafoods
Kenmore, WA
Ketchikan, Naknek
Small
700 peak, less than 500 average
NA
Alaska Glacier Seafoods
Juneau
Juneau
Small
NA
NA
Coastal Fisheries, LLC (Pacific Sun)
N/A
Ketchikan
NA
NA
NA
Copper River Seafoods
Cordova and Anchorage
Cordova,  Anchorage
Small
175 seasonal
$50-$100
E.C. Phillips and Son, Inc.
Ketchikan
Ketchikan
Small
200-250 seasonal
NA
Icicle Seafoods [a]
Seattle, WA
Petersburg, Seward (Kenai Peninsula)
Large
500+
$400
Ocean Beauty Seafoods
Seattle, WA
Alitka, Cordova, Excursion Inlet, Kodiak, Naknek, Petersburg, and Nikiski (Kenai Peninsula)
Large
500
$400
Alaska Seafood Holdings (Taku)
NA
Juneau
NA
NA
NA
Trident Seafood
Seattle, WA
Cordova, Ketchikan, Naknek, Akutan, Sand Point, St. Paul, Kodiak, Chignik, and Wrangell

Large
2,510
$1,000
Additional Firms with Facilities in Locations of Interest
Double E Seafoods, LLC
Seattle, WA
Pacific Star, Kenai and Yakutat Seafoods, Yakutat
NA
NA
$100
Inlet Fish Producers
Kenai
Kasilof and Nikiski, AK
Small
200
NA
Maruha Nichiro Holdings (Alyeska and Westward)
Japan
Alyeska Seafoods, Dutch Harbor, and
Westward Seafoods, Dutch Harbor  and Kodiak
Large
14,094
$8,940
Nippon Suison Kaisha
Japan
UniSea Seafoods, Dutch Harbor
Large
8,801
$5,195
Marubeni Corporation (North Pacific Seafoods)
Japan (Seattle, WA)
Sitka, Kodiak, Togiak, and Pederson Point
Large
5,679 (parent)
$35,384 (parent)
Polar Equipment
NA
Kenai Peninsula, AK
NA
NA
NA
Seafood Producers Cooperative
Sitka
Sitka
NA
NA
NA
NA indicates information that is not publicly available.
[a] Icicle Seafoods is owned by parent company, Paine & Partners.
[b] North Pacific Seafoods is owned by the Marubeni Corporation.

Firms Owning Petitioning Processing Location Facilities
Nine firms operate the 14 petitioning location facilities discussed above. Trident Seafoods Corporation owns five of the facilities (two in Ketchikan, two in Cordova, and one in Petersburg) and Ocean Beauty owns two (Cordova and Petersburg). The remaining firms operate one facility each in the petitioning locations, even though some of them own other facilities outside the petitioning locations. The facility information for the Alaska Glacier and E.C. Phillips facilities in Section 3.1.1 reflects the information available for the owner firms and is not repeated here. No publicly available information is available for Coastal Fisheries, LLC, the owner firm of the Pacific Sun facility or Alaska Seafood Holdings, which owns Taku.  Some additional firm-specific information is available on the other six firms operating discharging facilities in the petitioning locations, which is presented below.  Of the nine firms, six were surveyed (including Trident, Icicle, Ocean Beauty, E.C. Phillips, Copper River Seafoods, and Alaska Glacier). Based on the survey information provided on the firm-level finances, EPA has determined that the firms were not in financial distress as of 2009 (U.S. EPA, 2011). EPA cannot provide additional financial details in order to protect confidential business information. All information presented here is from corporate websites (see Section 3.1.1) or is cited separately.
Alaska General Seafoods -- Alaska General is based in Kenmore, Washington and operates two land-based processing locations in Alaska: one in Ketchikan and the other in Naknek (Bristol Bay, a processing location currently classified as remote). The company also operates a fish camp in Egigek, where housing, food, and boat storage and repair are supplied to fishermen. The company, which employs an estimated 700 workers during peak fish production, produces fresh, frozen, and canned fish products from salmon and herring it purchases from hundreds of fishermen. The products are sold in North America, Asia, and Europe.
Copper River Seafoods -- In 1996, three Alaska fisherman-owned and operated companies, Copper River Catch, Copper River Fine Seafoods, and Copper River Wild, collaborated to form Copper River Seafoods. With facilities in Cordova and Anchorage, where the corporate headquarters is located, Copper River Seafoods processes fresh, frozen and smoked seafood products (Copper River, 2010a). The company's revenues are estimated at $50 to $100 million and seasonal employees total an average of 175 workers between the two locations (Manta, 2011a).
   * Icicle Seafoods, Inc. -- Icicle Seafoods began in 1965 as a local fisherman-owned company, Petersburg Fisheries, Inc., in Petersburg, Alaska. The company was an early adopter of year-round processing and the use of floating processors which allowed fishermen to catch and process fish in the more remote areas of Alaska. Today, the company is owned by a private investment firm, Paine & Partners, and has estimated revenues of $400 million. Icicle employs an estimated 500+ year-round workers at its headquarters in Seattle, WA, its aquaculture facility in Washington, and at its land-based processing facilities in Seward, Homer, Egegik, Petersburg and Larsen Bay.  Icicle also has support sites at Ninilchik, Dillingham, Dutch Harbor, and Naknek (Hoovers, 2010a), but its website lists 500 employees (probably seasonal) at the Petersburg plant alone. The Petersburg plant is the only direct discharging facility owned by Icicle in the petitioning locations. The company also owns five floating processors. Icicle processes a variety of fish, including salmon, crab, pollock, halibut, and cod.  Its facilities process fresh, frozen, canned, and value-added products such as surimi. Icicle markets canned products under private, national, and Icicle-brand labels (Icicle Seafoods, 2010a).

Ocean Beauty -- Ocean Beauty Seafoods is based in Seattle, WA and began processing Alaska seafood in the 1930s. Today, the company employs an estimated 500 workers at its headquarters, seven distribution locations separate from its headquarters facility, several processing facilities in the lower 48, and seven processing plants located in Alaska. Those seven processing plants are located in Alitka, Cordova, Excursion Inlet, Kodiak, Naknuk, Petersburg, and Nikiski (Kenai).  The Cordova and Petersburg plants are discharging petitioning location facilities (with its Nikiski facility located in the Kenai Peninsula location of interest). The company produces fresh, frozen, canned, and specialty products from a variety of fish specific to each of the company's seven Alaska processing locations. Ocean Beauty revenues are estimated at $400 million and its products are shipped to the contiguous United States for national and international distribution (Hoovers, 2010e).
Trident Seafoods Corporation -- Founded in 1973, Trident Seafoods Corporation operates multiple processing facilities in Alaska and the Pacific Northwest. In Alaska, Trident operates during both winter and summer seasons to produce a variety of fresh, frozen, canned and value added products utilizing crab, salmon, cod , halibut, perch, pollock, rockfish, and sole. The company owns a total of ten processing plants in Alaska. Five are located in the petitioning locations, including two in Cordova, two in Ketchikan, and one in Petersburg, with the remaining five located in locations classified as remote or non-remote non-petitioning [Kodiak]. The primary processing plants include "a Southeast pink salmon cannery in Ketchikan; Bristol Bay sockeye salmon canning and freezing operations in North and South Naknek; diversified processing plants handling Alaska pollock, Pacific cod, Black cod, halibut and crab in Akutan, Sand Point, Kodiak and St. Paul; and groundfish processing in Kodiak." Trident also operates four by-product processing plants, located in Akutan, Chignik (on the Alaska Peninsula heading out towards the Aleutians), Cordova, and Wrangell (near Petersburg). Another by-product recovery facility is being built in Naknek. Trident currently employs an estimated 2,510 workers with company revenues reaching $1 billion (Trident, 2010c; Hoovers, 2010f, Trident 2012)
Other Firms Owning Remote Facilities in Procressing Locations of Interest (Dutch Harbor, Kenai Peninsula, Sitka)
Sixteen firms own discharging facilities in the remote locations of interest. Several of these firms, some of which are owned by parent companies, were either surveyed as the owner of a petitioning location facility or as an owner of a facility in a location of interest.  Surveyed firms are noted in the discussions below. EPA obtained all information obtained from corporate websites (see Section 3.1.2) unless otherwise cited.
Dutch Harbor
Four firms own the three existing facilities and one newly opened facility in Dutch Harbor. Three of these firms are, in turn, owned by two large Japanese firms. The newly re-opened Bering Star Fisheries (formerly Harbor Crown Seafood) floating processing facility [see pg 19]  is owned by Copper River and Siu Alaska under their joint venture, Dutch Harbor Acquisitions LLC (Siu Alaska Corporation, 2011). Additional profile information is not readily available for Siu Alaska or the jointly held corporate entity.  Although two of these firms, Alyeska and Westward, as well as their parent were surveyed, EPA has not assessed the financial health of these firms at this time.
Maruha Nichiro Holdings (Alyeska and Westward Seafoods) -- One of Japan's largest seafood producers, Maruha Nichiro was established in 2007 when Nichiro and the Maruha Group merged. The company has four divisions, including fishery operations (fresh, frozen, and canned products), food operations, meat (chicken, pork, and processed meats), and storage and logistics. Maruha Nichiro has fishing and aquaculture operations in Japan, Alaska, and China. The company has two seafood processing subsidiaries in Alaska: Alyeska and Westward Seafoods. Maruha Nichiro currently employees approximately 14,094 workers with annual revenues reported at $8,940 million. Top company competitors include Nippon Suison Kaisha, which also operates a seafood processing plant in Alaska (UniSea). Its subsidiary, Alyeska Seafoods, also processes fresh and frozen crab in its Dutch Harbor facility. This subsidiary employs 340 workers and its annual revenue information is not publically available (Hoover's 2011). Westward Seafoods also operates a processing facility in Kodiak. The main processing plant is its Dutch Harbor facility, which focuses on Alaskan pollock.  Its Kodiak location processes a variety of finfish and shellfish from the Bering Sea and Gulf of Alaska. The company employs an estimated 220 workers. Information pertaining to annual revenues is not publically available. Both Alyeska and Westward, along with their parent company and other subsidiaries and facilities owned by Maruha Nichiro, were surveyed.
Nippon Suison Kaisha (UniSea) -- Nippon Suison Kaisha, more commonly known as NISSUI, is the second largest producer of marine products in Japan. Production of fresh and frozen seafood products accounts for one-third of the company's $5.2 billion annual revenue. The company owns the U.S. fish company, Gorton's, and is the parent company to Alaska seafood processor, UniSea. NISSUI employs 8,801 workers and, aside from seafood, has business segments involved in chemical and pharmaceutical production, cold-storage, third-party logistics, engineering services, and shipbuilding and repair. UniSea, its wholly owned subsidiary, processes cod, halibut, pollock, snow and king crab, and surimi as well as white fishmeal and fish oil in Dutch Harbor, AK. It also maintains a cold storage facility in Redmond, WA. The company obtains its catch from a variety of independent Alaskan fisherman and listed 40 vessels as its fleet in 2001. UniSea employs an estimated 600 to 1,200 workers. Employment varies according the fishing seasons' production levels. UniSea products are marketed under the brand titles UniSea, Dutch Harbor, and GLS. Fish oil is recovered from the waste and is marketed in Taiwan and Japan and also fuels the processing plant. Information pertaining to annual revenues is not publically available.
Kenai Peninsula
Nine firms own the 10 discharging facilities in the Kenai Peninsula. Three of the firms owning the Kenai Peninsula location facilities are single-facility firms, including The Fish Factory, Salamatof, and Snug Harbor, which EPA surveyed. The information presented for the facility applies to the firm and is not repeated here. Another two firms, Icicle and Ocean Beauty (also surveyed), were discussed previously. No public information on the owner firm for Polar Seafoods was found. The remaining three firms are discussed here. The details of the financial status of firms owning facilities on the Kenai Peninsula processing location that were surveyed are not discussed to protect confidential business information, but they are not considered to be currently (2009) in financial distress (EPA, 2011).
Double E Seafoods, LLC (Pacific Star) -- Based in Seattle, WA, Double E Seafoods focuses on Alaska and North Pacific Seafood. Also known as E & E Seafoods, the company's services include fresh and frozen seafood processing, marketing, and import export services. Sales from all Alaskan facilities in 2008 are reported at $100 million (Double E Seafoods, 2010b). Double E Seafoods is the parent company for both Pacific Star and Yakutat Seafoods, which is classified as remote and is located between the northern end of the Inside Passage and Cordova. EPA did not find Double E Seafoods employment numbers in publicly available information.
Pacific Seafood Company (Sea Level Seafoods) -- Pacific Seafood Company owns Sea Level Seafoods, which in turn owns the Resurrection Bay facility (EPA's CBI economic impact results report uses the Sea Level Seafoods name for this facility).  Pacific Seafood Company reports that it operates processing plants "stretching along the Pacific Coast from Alaska to Mexico and distribution facilities in Washington, Oregon, California, Utah, Nevada, Arizona & Texas," with its headquarters located in Oregon. EPA did not find information on revenues and employment.
   * Inlet Fish Producers -- Inlet Fish Producers operates two processing plants, one on the Kenai River and the other on the Kasilof River. Both are considered to be located in the Kenai Peninsula processing  location. The plants process salmon from May through September as well as halibut. Approximately 250 seasonal employees work at these facilities. Annual sales are estimated at $9.6 million (Hoovers, 2010g). This firm was surveyed.
Sitka
Three firms own the three discharging facilities located in Sitka. No firms in Sitka were surveyed.
Marubeni Corporation (North Pacific Seafoods) -- The Marubeni Corporation is a Japanese general trading company with 11 divisions including: Chemicals; Energy; Finance, Logistics & IT Business; Food; Forest Product; Lifestyle; Metals & Mineral Resources; Real Estate; Plant, Ship & Industrial Machinery; Power Projects & Infrastructure; and Transportation Machinery. The company employed 5,679 workers in 2010 and its revenues are reported to be $35 billion. North Pacific Seafoods is Marubeni's subsidiary and is headquartered in Seattle, WA. With an estimated 800 employees, North Pacific Seafoods has four land-based processing plants in Alaska that are located in the remote and non-remote processing  locations of Sitka, Kodiak, Togiak (west of Bristol Bay), and Pederson Point (Bristol Bay area). Focusing on fresh, frozen, and value-added specialty products, the company catches, processes and distributes a variety of seafood products, including salmon, tuna, halibut, pollock, cod, rockfish, flatfish, crab, shrimp, caviar, squid, sea cucumbers, and roe.
Seafood Producers Cooperative -- The Seafood Producer's Cooperative states that the firm focuses on line-caught halibut, sablefish, salmon, rockfish and albacore. Its headquarters are located in Bellingham, WA. The firm claims to be "the largest and most successful fishermen's cooperative in North America [w]ith more than 500 extraordinary fishermen."
Silver Bay Seafoods -- Silver Bay indicates that it is a predominantly fisherman-owned firm and has additional facilities located in Valdez (near Cordova) and Craig, AK (near Ketchikan); both are in remote locations. The firm's focus is on salmon, but it also processes herring roe. The Sitka facility serves as corporate headquarters.  Revenues at this relatively new firm, established in 2006, are estimated at $16.8 million with a staff of 185 employees, who are most likely seasonal (Manta, 2011).
Current Industry Practices For Managing Waste
General Waste Management Practices
Researchers estimate that approximately 60 percent of the total weight of processed seafood resources is used for the intended fish product, while the other 40 percent is considered waste (Bimbo, 2008).  The processing waste generated includes unwanted seafood parts such as heads, fins, shells, and bones. The amount of waste generated varies by the type of seafood species processed as well as the product being produced. Globally, an estimated nearly 60 million tons of seafood processing waste is generated per year. Alaska alone produces more than one million tons of fish processing waste annually (Bimbo, 2010).
The choice of seafood waste management methods involves economic considerations, with the cost of a disposal method (e.g., grinding and near-shore discharge of the resulting wastewater or screening and nearshore discharge of resulting wastewater and offshore disposal, or the cost to process the screened solids for reuse in by-product recovery) taken into account. Fuel and vessel operating prices (e.g., labor), equipment costs (for grinding or secondary processing), and offsetting income from by-product marketability (and, thus, potential revenue from sale of recovered by-products offset costs of that processing), factor into the processors' disposal decisions. Other, non-economic, factors also play a role. These include regulations, such as the ELGs, local requirements, and the availability of cooperative, or collective, by-product processing, where several seafood processing facilities make use of by-product processing facilities operated by other firms. The availability of collective by-product processing, in turn, contributes to economic decision making. Historically, fish wastes have been disposed of through offshore disposal or discharge. Emerging markets, however, have begun to capitalize on the beneficial nutrients in fish wastes such as proteins, omega three fatty acids, and phosphorous (species dependent) resulting from fish waste that can be processed into secondary products or by-products (Bimbo, 2008). The next section begins by describing the principal seafood by-products including fishmeal, bone meal, fish oil and hydrolyzed protein, plus five others. This is followed by a discussion of the market for by-products, current by-product facilities in Alaska, and volume of Alaskan seafood by-products available for future markets.
Seafood By-products
Fishmeal
"Fishmeal is a brown powder obtained after cooking, pressing, drying and milling fresh raw fish and/or fish processing waste" (IFFO, 2010). Fishmeal is made most frequently through a wet process where the fish waste is cooked so that the fish oils and water in the fish are released, and the proteins start coagulating. The coagulated mixture is then separated by pressing the solids into a press cake. Any remaining liquids and solids are placed in a decanter where the oils are separated through centrifugation. The resulting oil is added back to the presscake. The presscake is then dehydrated and milled (FAO, 2010).
Fishmeal is a desirable product because it contains protein (60% to 2%), omega 3 fatty acids, vitamins, and minerals (Bimbo, 2008; IFFO, 2010). The grade and quality of fish meal depends on the sources and types of fish used to make it. The types of fish used to produce fishmeal are often oily, boney fish (such as menhaden and anchovies) that are not in high consumer demand for consumption. Fish trimmings from whitefish and herring (which have lower oil content) comprise, roughly, 25 percent of fishmeal content produced (IFFO, 2010).
Due to its nutritional value, fishmeal can be used as a feed ingredient for farm animals to balance dietary needs, and more recently, it has been used as feed for fish in hatcheries (although fish cannot be fed fishmeal made from their own species) (Bimbo, 2008; IFFO, 2010).
Bone Meal
When fishmeal is screened to remove the bones, the resulting bone material can be ground to form the product known as bone meal. Fish bones are often removed during processing to increase the protein content and reduce phosphorus levels of the product being made (Bimbo, 2008). Bone meal may be used as a feed additive or in products such as fertilizers as protein and mineral supplement.
Bone meal traditionally has been produced from ruminants, but since the outbreak of mad cow disease, Canada, the United States, and Europe have prohibited meals made from those sources, creating a market opportunity for fish meals (Finstad et. al., 2010). Bimbo (2008) also notes the benefits of using bone meal as a mining and petroleum waste water treatment to remove metals. This potential in-state use in of bone meal Alaska would also be beneficial because it would help reduce product shipping costs of the bulky material.
Fish Oil
Fish oil is extracted from fish processing wastes using several different methods as described by Sathivel et. al.: "(1) ground fish are homogenized with water, the homogenized mixture is centrifuged, and fish oil is separated; (2) ground fish (no added water) is heated and centrifuged, and fish oil is separated; (3) fish oil is extracted by rendering; and (4) ground fish is hydrolyzed using commercial enzymes and the oil collected by centrifugation" (Sathivel et. al., 2010).
Fish oils are divided into two main categories: commodity oils and nutraceutical oils.  Commodity oils are bulk oils which themselves are divided into two types: food grade and non-food grade.  Food grade oils must be produced under carefully controlled circumstances (e.g., input materials iced or kept under refrigeration) and are regulated by the Food and Drug Administration. Non-food grade oils have few handling requirements.  Nutraceutical fish oils also go through additional refining processes compared to raw, commodity oils used in feed (Bimbo, 2008).
Fish oils have several uses, depending on their type. Fish oils high in Omega 3 fatty acids are used as a dietary supplement in feed for farmed fish. Refined nutraceutical fish oil is used to produce omega-3 health supplements and oils for human consumption (IFFO, 2010). In Alaska, non-food grade fish oil is often mixed with diesel fuel to extend energy sources that help fuel processing facilities (Bimbo, 2008). For example, the Alaska Energy Authority (AEA) reports that UniSea in Dutch Harbor uses fish oil, produced largely from pollock processing waste by its own by-product recovery facility, to replace about 50 percent of the volume of fossil (diesel) fuel that would be used to generate electricity to operate the processing plant (AIDEA, 2011). Trident's facility at Akutan near Dutch Harbor also uses fish oil to replace diesel fuel used to generate electricity to operate the processing plant.
Hydrolyzed Protein
Hydrolyzed protein, also known as fish hydrolysate, is created through the process of hydrolysis whereby proteins are broken down by adding strong acidic or basic chemicals or enzymes to fish waste in order to facilitate the breakdown process. This method allows the functional proteins of the fish waste to be extracted and converted into a soluble protein that can be integrated into both food and non-food products. Chemical hydrolysis is a relatively quick and inexpensive way to create a soluble protein; however, the taste can be bitter and cause some loss of the protein's functionality. This type of hydrolysis is used mainly for fertilizers. Enzymatic hydrolysis, on the other hand, is easier to control than chemical hydrolysis. While it is more expensive, enzymatic hydrolysis may be used to produce products such as sauces, silage, and fish feed. Current studies are gauging the protein functionality, taste, and solubility of products made using the enzymatic method (Sanmartin et. al., 2009).
Montlake Process
The Montlake Process "combines wet reduction technology, acid stabilization, and drum drying of fish waste" to produce high protein - low ash meal, oil, and gelatin (Nicklason et. al., 2010). The process de-bones muscle-containing fish and then cooks and decants the recovered muscle tissue to produce meal cake and oil. Nicklason et al go on to describe the remainder of the process as follows:
      "Raw wet viscera are ground and combined with the decanter cake to form a blended meal. The blended meal can be immediately dried on a drum dryer or stabilized with 0.8% formic acid and stored for later drying. The finished meal is high in protein and low in ash, and has good binding properties that allow a rugged feed particle to be extruded with no added gelatinized starch as is the case with conventional fish meal - based feeds. In a separate processing line, a crude gelatin fraction is extracted from the bones by wet heat and straining. The crude gelatin is also dried on a drum dryer. Short-term storage of material reduces equipment requirements and increases working days for a given amount of material. This, in turn, allows the design of portable process units that can service more than one fishery and further extend operating days."  (Nicklason et. al, 2010).
Compost and Crop Nutrient
Fish processing by-products such as fish and bone meal, hydrolysates and fish oils have proven to be beneficial as a compost, fertilizer, and crop nutrient in both Alaska and the broader United States. These by-products can increase nitrogen and micronutrient (such as calcium and zinc) levels in soils (Zhang et. al., 2010).
Modified Silage
Modified silage is created by adding organic compounds to fish waste to slow the breakdown of proteins and bacterial activity. By slowing this process, the modified silage is stable enough for transport to a facility that can process it into fishmeal or oil (Browning, 2010).
Chondroitin Sulfate (CS)
CS is an important structural component of connective tissues, such as cartilage, and has become a dietary supplement commonly taken for osteoarthritis. Stine et al show that fish heads resulting from seafood processing are a viable source of CS (Stine et. al., 2010).
Dried Salmon Fish Heads
A by-product of fish processing, salmon fish heads contain healthy lipids associated with brain development, decreased cardiovascular disease, and retina development in infants.  With annual tons of salmon fish heads numbering near 65,000 tons, researchers have been experimenting with a variety of drying temperature techniques (Smiley et. al., 2010).
Chitin
Chitin is a natural biopolymer with a chemical structure similar to that of cellulose and is recovered mainly from the shells of crabs and shrimp. According to Troger and Niranjan (2010), "in order to obtain purified Chitin, it must be separated from the proteins, minerals and other components. This separation is achieved in three steps: 1) de-mineralisation to eliminate the calcium carbonate, 2) de-proteinisation, and 3) elimination of lipids and decolourisation." Chitin can be extracted from these seafood shells chemically or biologically. "Chemical extraction uses inorganic acids for de-mineralisation, alkali for de-proteinisation and organic solvents for the elimination of lipids and color" while biological extraction involves fermentation and enzyme extraction (Troger and Niranjan, 2010).
Alaska has not been a major player in the chitin industry because financial considerations make it more cost effective to ship the shells to China and to produce products there (FITC, 2010).
Markets for Seafood Processing By-products
Three by-product markets are discussed in this section: fishmeal, fish oil, and hydrolysate, because they are the by-products currently being made in any notable volumes by Alaska by-product producers. Although established markets for traditional seafood by-products such as fishmeal and fish oil do exist, markets for non-traditional by-products such as hydrolyzed protein are still emerging (Bimbo, 2008). Fishmeal and fish oil have overlapping market attributes resulting from their co-production processes (fish oil is a by-product of fishmeal production). Markets for products such as hydrolyzed protein, however, are not well quantified in market studies. This section begins with a discussion of the markets for fishmeal and fish oil, followed by a brief discussion of the hydrolyzed protein market.
Fishmeal
According to the Food and Agriculture Organization (FAO) the demand for fishmeal is one of the drivers of the entire fish sector because 25 percent of capture fisheries enter into fishmeal production (FAO, 2010). More than half of global fishmeal produced is used as feed in aquaculture (FAO, 2010). Aside from aquaculture, premium markets for fishmeal also include feed for early weaned pigs, poultry, and ruminants; as well as egg production that focuses on increasing Omega 3 content (Bimbo, 2010).
Annual global fishmeal production for 2009 is estimated at 6.5 million tons (Bechtel, 2010). The main supply of seafood for the current fishmeal market comes from Peruvian anchovies. Other main producer-exporter countries for fishmeal include Chile, Iceland, Norway and Denmark. Figure 4 shows the relative production levels between the top fishmeal-producing and exporting countries (FAO, 2010).
Figure 4. Top International Fishmeal Producers 2006-2009

                 Source: IFFO data as published in FAO, 2010.
Source: IFFO data as published in FAO, 2010.

Recently, fishmeal production has been decreasing while its price continues to increase. Two main factors contributed to the decline in fishmeal production during 2009 and 2010.  First, Peruvian fishmeal production has been negatively affected by weather near South America which has increased ocean temperatures, thereby decreasing the fish catch used to create fishmeal. Adding to the decreased fishmeal production on a global scale is the decline in Chilean fishmeal production that has resulted from a recent earthquake. With Chilean production levels estimated to decrease nearly 200,000 tons in 2010, more production pressure is falling onto the already-diminished fishmeal quantities generated by Peru (FAO, 2010; IFFO, 2010).
Fishmeal prices are expected to rise as the result of shrinking quantities of fishmeal production and the increasing product demand by China (which imports 50 percent of world fishmeal production). The FAO reports that some Chinese ports are paying record high fishmeal prices of $1,900 per ton for the highly desired product (FAO, 2010). With product supplies uncertain in the future, fishmeal prices are expected to continue rising.
In addition to an international market, the United States also presents a potential fishmeal market for Alaskan fishmeal. In 2008, the United States imported more than 38,000 tons of fish meal. The majority of fish meal was imported from Mexico (22,000 tons) with Chile (5,500 tons) and Canada (2,000 tons) rounding out the top-three exporters to the United States (FAO, 2010).
Several potential markets for fishery by-products exist within the United States. First, fishmeal can be used as a nutritional supplement in domestic livestock and aquaculture feed production. The United States is the largest producer of animal feeds in the world, and in 2007, leading U.S.-based feed manufacturers produced more than 53 million tons of animal feed. Bimbo (2008) suggests that fishmeal markets should tap into the country's livestock hubs such as Pennsylvania, Michigan, and Minnesota which each produced more than two million tons of livestock feed in 2005. Fishmeal could also be used for domestic aquaculture feed and supplements. In 2007, more than 1,800 aquaculture operations produced catfish and trout alone (Bimbo, 2008).
Bimbo (2008) calculates the average price of fishmeal during the years 2002 to 2007 using prices from OilWorld.biz. Bimbo's (2008) price average for meal was $966 per ton, or $866 when subtracting $100 for freight (as estimated by Bimbo). This price is considered a reasonable estimate of the price for Alaskan fishmeal products over the next few years, with some potential for this price to rise over time.
Fish Oil
Similar to the fishmeal industry, the five countries responsible for exporting the majority of the world's fish oil are: Peru, Chile, Iceland, Norway and Denmark. Together, these countries exported 530,000 tons of fish oil in 2009 -- a 100,000 ton decline from the previous year. Chile and Peru both reported a ten percent decrease in fish oil production during 2009, and Scandinavian countries contributed to global declines with a 30 percent decline in oil production. As fish oil production has decreased, its market price has also increased (FAO, 2010).
Fish oil prices are often compared to soybean oil because they are competing products in the market place and exhibit similar trends (Bimbo, 2008). While fish oil prices were $120 per ton below soybean oil prices in 2009, by March 2010, fish oil prices had risen above soybean oil prices, fetching $950 per ton, or twice as much as 2009 prices (FAO, 2010). The FAO attributes this price increase to changes in South American water temperatures that have reduced fish stocks used to produce fish oil (as is the case with fishmeal) (FAO, 2010). FAO (2010) expects prices to continue to rise due to this factor.
A fish oil's composition contributes to its marketability and value. This composition can be affected by a variety of factors relating to the fish (such as the fish species, its aquatic environment, seasonal variations in weather, and geographical location) and how the fish is processed (Kim and Mendis, 2006). These factors contribute to the product's overall quality and nutritional properties, such as the percentage of protein or the amount of fat contained in the product. Commodity oils and nutraceuticals often have different compositional requirements. For example, raw commodity oils, such as those used in aquaculture, need to be low in oxidation and contaminants. Although nutraceutical fish oils also have these same requirements, the nutraceutical market also seeks oils that have high levels of omega-3 fatty acids and come from pristine natural resources.
Nutraceutical oil  comprises approximately five to10 percent of total fish oil production, and U.S. Customs information indicates that the volume of imported nutraceutical oils has more than tripled (from 4,000 tons to 15,000 tons) from 2002 to 2008 (as cited in NMFS, 2010; Bimbo, 2008). Price information for nutraceutical oils, however, is not as readily available as commodity fish oil prices. Due to the variation in quality and refinement beyond raw, commodity oils, nutraceutical oils often achieve a higher price point in the marketplace. Bimbo (2008) notes that prices for nutraceutical oils vary from "lows of one to two dollars per kilogram (kg) up to and exceeding $15 per kg."  This translates to $907 to $13,608 per ton, which is approximately the same as or much more expensive than prices for commodity oils). U.S. Customs estimates that, with the increase in the volume of imported oil from 2002 to 2008, the aggregate value of that oil also rose from approximately $15 million in 2002 to $95 million in 2008 (as cited in NMFS, 2010).
Fish oil currently also is used as a fuel supplement at processing plant locations where on-site generation of electricity is necessary  where power grid capabilities either may be severely limited or there is no available power at all. The Alaska Energy Authority (AEA) notes in its Renewable Energy Atlas, for example in 2009 and 2011, that many coastal locations offer the opportunity to use biomass (e.g., fish waste and the oil produced from it) as an important supplemental source of fuel to replace a portion of the fossil fuels used for energy generation. For example, all three long-standing processors in Dutch Harbor use fish oil produced primarily from pollock waste to replace a substantial portion of fossil fuel (diesel) normally used to generate electric power to run the processing plants. The by-product recovery facility in Kodiak also uses fish oil generated from pollock waste as the majority of fuel for on-site generation of electric power for that by-product recovery facility.
Bimbo (2008) estimates the average price of commodity oil during the years 2002 to 2007 using prices from   Oilworld.biz. Bimbo's (2008) price average for fish oil was $957 per ton, or $857 when subtracting $100 for freight (as estimated by Bimbo). This price is considered a reasonable estimate of the price for Alaskan oil products over the next few years, with some potential for this price to rise over time.
Alaska presents a potential resource for the world's commodity grade oil and meal markets as well as the growing market for high quality, refined salmon oil. As noted earlier, companies producing nutraceutical preparations favor fish oils with high levels of omega-3 fatty acids from pristine resources, and Alaska's environment and fish stocks meet those requirements. Alaska salmon and pollock provide a readily available source of high quality fish that, because of the cold water fisheries from which they come, have high levels of omega-3 fatty acids (Bechtel, 2010). Additionally, Alaska salmon and pollock are certified by the Marine Stewardship Council as coming from a sustainable resource (Bimbo, 2010). Bimbo (2008) states, however, that current Alaskan fish oil would need to be refined beyond current processing in order to meet nutraceutical standards.
Hydrolysate
As mentioned in the beginning of this section on by-product markets, no established market currently exists for non-traditional products such as hydrolysate. Bimbo (2008) notes two hydrolysate market considerations, including: 1) "hydrolysates...must be market driven since they are either very high in water content (silage) or bulky thus making transportation costs a key factor", and 2) "hydrolysates must be further processed to remove bones, oil and insoluble materials before drying. This involves more capital costs, increased energy costs and further disposal issues with the residual by-products." With little to no pricing or market information regarding hydrolysate from Alaskan producers, EPA assumes for the purposes of this profile, that there is a market (albeit currently small) for hydrolysate and that the market price for the product, at a minimum, covers the cost of producing the by-product.
Alaskan By-product Market Considerations
The financial viability of Alaskan by-products, such as fish oil, faces several economic considerations in the marketplace. Alaska's energy costs exceed most energy prices within the contiguous United States, and these costs vary according to particular regions within the state. Capital costs make building by-product facilities and certain equipment investments less desirable to potential by-product producers (Bimbo, 2010). By-product plants are designed to run continuously and flows of fish are not necessarily predictable or continuous (especially due to seasonal variation) (Lane, 2010).  Transportation costs associated with fuel and vessel costs might require resulting products to be lighter, less bulky, or able to withstand longer periods of time between processing phases. Additionally, profit margins reportedly have been thin throughout the state and vary from year to year (ADEC, 2010).
Number of By-product Processing Facilities
Alaska had 17 processors dedicated solely to producing fishery by-products in 2009, including 12 fishmeal processors and five fish oil processors (SFS, 2010; DCCED, 2010). The types of by-products produced by the plants include fish protein meal, fish oil, fish bone meal, and stickwater. These by-products are used to make consumer products such as commodity and nutraceutical oils, animal feeds (including feed used in aquaculture), and fertilizer/compost (Bechtel, 2010; FITC, 2010).  According to Alaska's Office of Fisheries Development, in 2009 fishmeal processors generated 31,100 tons of product produced from all seafood species, with a value of nearly $39 million. Fish oil producers in the same year produced 10,300 tons of oil worth $7.5 million.
The volume of fishmeal produced in Alaska generally has been declining since 2002, when it was more than 59,584 tons, or nearly twice as high as 2009 production levels. The 2009 production level of 31,100 tons is roughly one percent of global fish meal production (DCCED, 2010; FAO, 2010). Alaska's fish oil market is similarly positioned, with approximately one percent of global fish oil production (DCCED, 2010). However, the volume of Alaskan fish oil produced is increasing and has nearly doubled since 2000.
Many of the current fishmeal and fish oil operations in Alaska are the result of ADEC requirements that coincided with the Americanization of the groundfish fishery. The 1972 Clean Water Act led to conservation measures such as the Magnuson Fisheries Conservation and Management Act of 1976 and, thereafter, the 200-mile Exclusive Economic Zone (EEZ). As a result of these measures, seafood processing facilities, predominately in Western Alaska surrounding the Bering Sea and Gulf of Alaska, began processing high volumes of groundfish. ADEC required these operations to integrate by-product recovery systems to process fish meal and fish oil. Recovery operations with fish types that are harvested year-round are also able to run recovery operation year round if the total of volume of waste is sufficient (Bechtel, 2010).
Currently, eight of the state's fishmeal operations remain in the Bering Sea and Gulf of Alaska region, mainly handling pollock, cod, and other groundfish. For example, Kodiak Fishmeal Company uses approximately 1,000 tons of fish waste per day to produce fishmeal from white fish and salmon, bone meal, and fish oil (Kodiak Fishmeal Company, 2010). These waste processing facilities process an estimated 400 tons of waste per day (SFS, 2010). Several plants also process waste streams from salmon products in coastal communities in the Gulf region (Bechtel, 2010). Alyeska, Unisea, and Westward all operate individual by-product recovery facilities in Dutch Harbor. Also, Trident operates by-product recovery facilities at the Akutan processing plant (U.S. EPA, 2001a), Chignik, Wrangell, and in Cordova. Trident also is building a new by-product recovery facility in Naknek.
In addition to the recovery operations in the Bering Sea and Gulf of Alaska, seafood processors throughout Alaska use their wastes to produce by-products, primarily from salmon waste. Many of the by-product recovery facilities in the non-remote petitioning locations and locations of interest covered in this profile fall into this category of co-produced by-products. These processors operate their by-product recovery operations mainly during salmon season. Although some processors use a variety of fish waste solids to produce meal and oil, other producers focus on certain types of waste, such as fish heads, which have more desirable nutrient levels.
Table 5 provides by-product recovery information for facilities in the non-remote petitioning areas as well as the remote areas of interest. The table describes the types of seafood processed by the facility and the resulting by-products.
Table 5. Facilities Producing Fishmeal and Fish Oil
Facility
Independent of Seafood Processing Plant?
Location
By-product(s)
Produced [a]
Seafood Processed
Alaska Protein Recovery/
Trident Seafoods
Yes**
Ketchikan
(barge, could relocate)
Salmon oil (food grade)
Salmon protein hydrolysate
Salmon heads (food grade)
Salmon waste
Alyeska[f]
No
Dutch Harbor
Fish meal
90% pollock waste
Icicle Seafoods
No
Petersburg
Salmon oil
Salmon meal
Salmon waste (mixed, non-food grade)
Icicle Seafoods
No
Seward
Salmon oil
Salmon meal [c]
Salmon (roe stripped)
Salmon waste
Bottom fish waste
Sitka Meal, Oil, and Gelatin
Yes
Sitka (planned)
Salmon oil (food grade)
Salmon meal
Crude (6%) chondroitin sulfate-rich gelatin
Salmon waste
White fish waste
Scientific Fisheries[b]
Yes
Kenai
Salmon oil (food grade)
Salmon meal [d]
Salmon heads (food grade)
Snug Harbor
No
Kenai
Fertilizer (compost)
Salmon waste
Trident Seafoods
No
Akutan, Cordova, Chignik, Wrangell, Naknek [f]
Salmon oil (food grade)
Salmon protein hydrolysate [e]
Fish meal
Salmon heads (food grade)
Salmon waste
UniSea
No
Dutch Harbor
Fish meal
Bone meal
Fish oil
Pollock collagen
90% pollock waste
Some crab
Other fish
Westward
No
Dutch Harbor
Fish meal
Bone meal
Fish oil
90% pollock waste
Some crab
Other fish
Source: U.S. EPA, 2010
*Raw and processed seafood that is managed as food grade is noted as such and is otherwise considered to be non-food grade.
** It should be noted that APR is partly owned by Trident Seafood Corporation.
[a] The white fish oil is not a marketed by-product but, rather, it is typically burned in the plant's boilers (FITC, 2010).
[b] Operates plant for Alaska Marine Nutrition.
[c] <5% of by-products are white fish meal.
[d] Meal production is planned for 2011.
[e] The hydrolysate produced is acid hydrolyzed fertilizer grade and enzyme hydrolyzed animal feed grade and is marketed by Alaska Protein Recovery.
[f] U.S. EPA, 2001, U.S. EPA 2001a; Trident letter to Bristol Bay Borough, January 24, 2012; facility not yet operating in Naknek
 Current By-product Processing in The Petitioning Locations and  Additional Locations of Interest
This section describes the seafood processing facilities within the petitioning locations as well as the locations of interest and their current by-product recovery efforts. This section highlights which operations currently are practicing by-product recovery, and discusses potential by-product recovery options for facilities currently not processing by-products. The facilities are discussed by location.
Status of By-product Recovery in the Petitioning Locations
Cordova
As noted earlier, four seafood processing facilities are located near Cordova: Copper River Seafoods, Trident Cannery (Trident North), Ocean Beauty Seafoods, and Trident Norquest (Trident South). With only 0.6 miles separating the northernmost and southernmost of these plants, joint by-product recovery in this center is a possibility, assuming corporate cooperation is feasible. Currently, Trident runs a recovery plant that operates only during salmon season and has previously taken waste from other area processors.
In 2009, Trident started up a by-product recovery plant located next door to the Trident Cordova North plant. Trident's Cordova facility uses Alaska Protein Recovery's (APR) proprietary process to produce fish oil and fish hydrolysate (Lane, 2010; Trident, 2010). The size of the by-product plant in Cordova was based on the capacity of the Trident cannery, which was 1.5 million lbs of raw fish per day (Lane, 2010).
Both the Trident Cordova North and Cordova South plants supply seafood waste to the Trident by-product recovery plant. Waste is transported from the Trident cannery (Cordova North plant) to the plant through three stainless steel pipes. Fish heads are transported separately from combined guts, frames, and skin (Trident, 2010). In 2010, Trident South trucked all salmon heads to the Trident North by-product recovery plant, and in 2011, it plans to truck the frames as well (Trident, 2010a). Trident South may also truck black cod heads. Trident Cordova South processes 400,000 to 500,000 lbs of black cod per year, resulting in 40,000 lbs per year of heads (Trident, 2010a). The heads are more than three percent oil, so it may be possible to recover the oil from the cod fish heads profitably (Trident, 2010a).
The Ocean Beauty plant is adjacent to the Trident recovery plant. Ocean Beauty sent its processing waste to Trident in 2009 and ground and discharged their waste through an NPDES permitted outfall in 2010. Ocean Beauty would like to send waste fish heads to Trident again in 2011 (Ocean Beauty, 2010).
Juneau
Juneau has two small direct discharging seafood processing plants that are nearly 14 miles apart. Taku is located in the heart of downtown Juneau and Alaska Glacier is located northwest of the city in an area known as Auke Bay (see Figure 3). Despite the distance, the two seafood processing facilities have access to a good roadway, thus there may be some potential for these processors to establish cooperative by-product recovery.
Currently, Alaska Glacier accumulates waste in totes on the dock, runs it through a grinder and pumps it into a bow picker (small boat). The boat transports the ground waste to beyond Portland Island where it is pumped out of the boat. The Taku Fisheries plant, which is located immediately adjacent to the cruise ship docking area and the Mount Roberts tramway in downtown Juneau, grinds its waste through two grinder pumps and discharges the ground waste through its NPDES-permitted outfall located approximately 60 feet off the dock at a depth of 60 to 80 feet (Taku, 2010).
Petersburg
Petersburg's three seafood processors, Icicle, Trident Norquest, and Ocean Beauty Seafoods, are located near each other, with approximately one half mile between the Icicle and Ocean Beauty facilities and the Trident facility located between them. Distance is not an issue for joint by-product recovery, but currently, Icicle, which has the only existing by-product processing capability in the location, is not processing other facilities' seafood wastes.
Icicle operates a by-product facility during salmon season and grinds and discharges waste through a NPDES permitted outfall during the remainder of the operating period. The by-product plant produces fish oil and fishmeal, which is used for aquaculture. The fish oil produced cannot be used for human food without additional refining. During salmon season, the plant has no additional by-product processing capacity, so as currently configured it cannot accept additional waste from its neighbors.
The two other plants currently are not recovering any fish waste. The Ocean Beauty plant did not operate in 2010 but is expected to operate during salmon season in 2011. This plant previously ground and discharged its processing waste through an NPDES permitted outfall and has not attempted any by-product recovery.  Sitka Meal, Oil, and Gelatin Company (SMOG), a potential by-product start-up firm to be located in Sitka (see discussion below in Section 4.4.2) has expressed interest in obtaining the waste from Ocean Beauty for its Sitka-based recovery plant (Stitzel, 2010). Trident has refurbished a salmon cannery in nearby Wrangell (less than 30 miles away), and the Petersburg plant has the potential to close to consolidate operations in Wrangell (Stitzel, 2010). If the Petersburg plant were to remain open, a recovery plant that could utilize the waste from both Trident operations potentially could be constructed, but no plans are underway.
Ketchikan
The five seafood processors in Ketchikan are located within a two mile area. Two processors -- Trident Norquest, and E.C. Phillips -- are located slightly west of downtown Ketchikan, as is the by-product processor, Alaska Protein Recovery (APR). The remaining three processors are just to the east of downtown: Alaska General, Pacific Sun Products, and the Trident salmon cannery. Approximately 1.8 miles separates the two most distant processors. Cooperative by-product recovery is occurring to some extent in this location. The downtown area of Ketchikan and the cruise ship docks are located between these two groups of processors.
The available by-product recovery processing capabilities in Ketchikan are represented by APR, a by-product recovery plant that is partly owned by Trident Seafood Corporation. The plant produces salmon oil and hydrolyzed fish protein.  It is located on a barge moored at the Trident dock and operates during the salmon season. The barge leaves when the season is over to deliver products to the Northwestern part of contiguous United States, and, more specifically, in 2010, hydrolysate to a buyer in California.
Nearly all of the Ketchikan facilities use APR for some or all of their wastes. The two major contributors to the waste stream processed by APR are the Trident Cannery and Alaska General.  Alaska General is the only non-Trident facility to send virtually all of its processing waste solids (exclusively salmon via a pipeline) to APR, sending its wastewater through a NPDES-permitted outfall. The Trident cannery also processes virtually all of its waste at APR.
Trident Norquest sends its fish heads, which are managed as food grade, to APR during salmon season. The remainder of the fish waste is ground and discharged through a NPDES permitted outfall. E.C. Phillips also removes fish heads and packs them on ice to be sent to APR for by-product recovery, and its remaining waste is ground and discharged shoreside (APR, 2010).
Only Pacific Sun Products does not provide any waste to APR. Currently, Pacific Sun discharges its fish waste through a NPDES-permitted outfall (APR, 2010; EPA, 2010).
Status of By-product Recovery in the Locations of Interest
Dutch Harbor
As noted in section 5.1, eight of the state's fishmeal operations are located in the Bering Sea and Gulf of Alaska region, mainly handling pollock, cod, and other groundfish. These waste processing facilities process an estimated 400 tons of waste per day (SFS, 2010). Three by-product operations are located in Dutch Harbor (See Figure 3).
As shown in Table 5, Alyeska, UniSea, and Westward generate a range of by-products, primarily from pollock. The three operations produce fishmeal, bone meal, and/or fish oil. UniSea, additionally, produces pollock collagen.
Kenai Peninsula
The Kenai Peninsula location encompasses several communities, including the cities of Kenai, Seward, and Homer. Ten discharging seafood processors are located in the Kenai Peninsula, including Ocean Beauty Seafoods in Nikiski, Snug Harbor Seafoods, and Icicle-Seward Fisheries. Although Ocean Beauty and Snug Harbor Seafoods are relatively near one another geographically, Ocean Beauty Nikiski and Icicle-Seward Fisheries are more than 100 miles apart with inter-connecting year-round roads.
The major by-product processing capability is associated with the Icicle Seward facility. Similar to the Icicle plant in Petersburg, Seward Fisheries operates a recovery plant during salmon season. Although Icicle has taken waste from other processors in the past, it no longer does so (U.S. EPA, 2010; Jordan, 1979).  Processors from the Kenai Peninsula and Anchorage previously drove their processing waste to the Icicle by-product recovery plant in Seward for disposal.
Scientific Fisheries Systems (SFS), a plant devoted to by-product processing (not seafood processing) is operating a salmon oil plant at Kenai Landing. This small scale, food grade salmon oil by-product operation is being operated by SFS for Alaska Marine Nutrition, LLC. The operation is within driving distance of the Kenai Peninsula seafood processing facilities, and the plant does not operate during the winter months. The recovery operation is currently taking waste from Snug Harbor Seafoods and, possibly, other area processors. In 2010, Snug Harbor provided Scientific Fisheries with 210,943 lbs (105 U.S. tons) of food grade fish heads. This represents about five percent of Snug Harbor's total waste (U.S. EPA, 2010). Snug Harbor reported that it also produces fertilizer onsite from seafood processing waste using a composting operation. Seafood processing waste is taken from the processing line, mixed with wood chips, and is placed in furrows on a fenced field next to the seafood plant. Snug Harbor placed about 30 tons of the waste-wood chip mixture into furrows in 2007 and has continued to place about 10 tons per year thereafter. The remainder of the processing waste is ground and discharged under a NPDES permit.
Sitka
The primary direct discharging processors in Sitka are Silver Bay and two other smaller plants (North Pacific Seafoods and the Seafood Producers Cooperative), which process approximately 15 million lbs of seafood per year (U.S. EPA, 2010). The longest distance between processors is the nearly six miles from the Seafood Producers Cooperative to Silver Bay Seafoods.
No by-product recovery currently is occurring in Sitka. One possible by-product recovery option for Sitka and, perhaps, certain other producers in nearby Inside Passage petitioning locations or elsewhere in Southeast Alaska, is the Sitka Meal, Oil, and Gelatin (SMOG) plant under consideration for construction. If it is built, the company intends to recover meal, oil, and gelatin from salmon waste. The plant would produce crude (6%) chondroitin sulfate gelatin by passing salmon heads through a bone separator and recovering chondroitin-rich cartilage (Stitzel, 2010). It is not yet known whether this by-product facility will materialize and become a viable by-product recovery option for nearby processors, however (Stitzel, 2010). The largest seafood processor in the location, Silver Bay Seafoods, currently is not interested in sending its waste for by-product recovery to such a plant if it were to be built due to a contract to sell a portion of its waste, with the remainder being ground and discharged (with waste hauling for offshore disposal as a backup method if it were to exceed permitted discharge volumes) (Stitzel, 2010; AIDEA, 2011).
Total Waste Available in Petition Processing Locations
Statewide, processing waste in Alaska ranges from an estimated 40 to 66 percent of the total weight of the fish being processed (Bimbo, 2008; Bechtel, 2010). The amount of seafood processing waste generated and available for the production of by-products varies by the type of seafood species processed as well as the seafood product being produced. For example, salmon that are only headed and gutted (H&G) retain about 65 percent of their weight for end products, while a considerably smaller percentage of pollock's total weight is retained. When these fish are used to produce fillets, about 50 percent of the salmon (by weight) and 20 percent of the pollock, are retained as product (FITC, 2010). For purposes of the processors covered in this profile, the main type of waste considered for by-product recovery is salmon processing waste.
In order to estimate the total salmon waste available by the processors in the petitioning  locations, the amount of raw seafood being processed must be obtained first. EPA consulted the two main sources of public information pertaining to the quantity and type of fish being processed in Alaska for this report. The first is the annual commercial catch numbers collected by the Alaska Department of Fish and Game (ADFG). Each year, AFDG records the volume of catch for herring, groundfish, salmon, and shellfish commercial fisheries. The volume of seafood (or landings), however, is recorded according to geographic regions which are not identical to the processing locations discussed in this profile. To estimate the volumes of seafood landed in petitioning areas, this analysis used ADFG regions that encompassed the petitioning processing locations[.] The processing locations and their corresponding ADFG regions are listed in Table 6. The other consideration in estimating the volume of fish landed for the petitioning locations using ADFG information is that halibut is excluded from the ADFG catch calculation because it is under the jurisdiction of the International Pacific Halibut Commission (IPHC). Although this profile is considering only salmon waste generated by the processing locations of interest, the IPHC areas best representing the petitioning areas have also been included in Table 6 to help illustrate the complexity of determining total processing waste by processing locations in Alaska.
Table 6. ADFG Regions Corresponding to Petitioning Locations
Processing Locations
ADFG Region
IPHC Area [a]
Juneau
Southeast
2C
Ketchikan
Southeast
2C
Petersburg
Southeast
2C
Cordova
Prince William Sound
3A
Source: ADFG, 2010; IPHC, 2010
[a] International Pacific Halibut Commission (IPHC)

Table 7 shows possible volumes of fish waste based on the volume of landings reported for entire ADFG regions and IPHC areas that correspond to the petitioning processing areas. Three cautionary points regarding the numbers in Table 7 are:
         * The percentages of regional processing waste corresponding to each petitioning processing location are unknown and, therefore, the numbers presented in the table indicate only the relative waste volumes from particular species within processing locations.
         * The percentage of waste per volume of landings captured by ADFG and IPHC was calculated using percentages of species waste estimated by Bechtel (2010). These percentages of waste may fluctuate by the form of processing, as Bechtel notes, so the numbers are only an estimate of potential waste.
         * Table 7 values were calculated using data from 2008 because this was the most recent year of complete data across species and entities. Fish volumes also fluctuate each year, so these values provide a snapshot of waste availability for a given time period.
Table 7. Estimated Seafood Waste from Regions Surrounding Petitioning Processing Locations in 2008 (tons)
                                   Location
                                    Halibut
                                  Groundfish
                                    Salmon
                                     TOTAL

                                    Lingcod
                                  Pacific Cod
                                   Rockfish
                                  (all types)
                                   Sablefish
                                Walleye Pollock
                               Misc. Groundfish

Prince William Sound
Cordova
3,051[a]
5
2
15
28
411
0
38,822
42,334
Southeast
Ketchikan
Petersburg
776
43
136
102
337
0
4
32,109
33,506
TOTAL
3,827
48
138
117
365
411
4
70,931
75,840
Source: ADFG, 2008; IPHC, 2008.
[a] IPHC data for Cordova is not for the ADFG Prince William Sound region, but rather area 3A (See Table 2)