Document DMjJR0yX844Zzve2Jx22vMy5Q
EPA REGION 10 Enforcement and Compliance Assurance Division
Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection
INSPECTION REPORT
06/08/2023 09:40 AM (PT)
Announced: No
06/08/2023 03:10 PM (PT)
Access: Granted
48F, Overcast, Misty
Water
Clean Water Act, NPDES, Industrial
Compliance Evaluation Inspection
Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code Borough Facility GPS Coordinates Mailing Address City, State, Zip Code
North Pacific Seafoods, Inc. Alaska Pacific Seafoods - Kodiak 627 Shelikof Street Kodiak, Alaska 99615 Kodiak 57.78526, -152.422192 4 Nickerson Street, Suite 400 Seattle, Washington 98109
FRS ID Permit Number
SIC
110000526574
AKG528434
2077 (Animal & marine fats & oils) 2092 (Fresh & frozen seafood processing (pt))
Lead Inspector:
RAYMOND ANDREWS Date: 2023.07.18 11:03:50 -07'00' Digitally signed by RAYMOND ANDREWS
Raymond Andrews
EPA Region 10
andrews.raymond@epa.gov
(206) 553-4252
Supervisor Review:
PETER CONTRERAS Date: 2023.07.18 11:06:46 -07'00' Digitally signed by PETER CONTRERAS
Peter Contreras
EPA Region 10
contreras.peter@epa.gov
(206) 553-6708
Alaska Pacific Seafoods - Kodiak AKG528434
SECTION I - Opening Conference
I arrived at the Alaska Pacific Seafoods - Kodiak (the "Site" or "Facility"), located at 627 Shelikof Street, Kodiak, Alaska, at 09:40 AM (PT) on 06/08/2023 for an unannounced inspection. I presented my credentials to Mr. Mitch Kilborn and informed him I was there to conduct an inspection to determine compliance with the Clean Water Act (CWA) and the Alaska Pollutant Discharge Elimination System (APDES) general permit for Seafood Processors Operating Onshore Facilities in Kodiak, Alaska ("Permit"), permit # AKG528434. This report is based on information supplied by Alaska Pacific Seafoods representatives, direct observations made by me, and records and reports maintained by the permittee. In addition, information gathered prior to or after the inspection from a review of EPA, State, and/or public records may be included in this report.
Attendees Organization EPA Region 10
North Pacific Seafoods North Pacific Seafoods North Pacific Seafoods
Attendee Name Raymond Andrews
Mitch Kilborn Matthew Moir Veena Salgatar
Title Lead Inspector Plant Manager General Manager EHS Coordinator
Present in Opening Conf.
Yes
Yes
Yes
Yes
Present in Closing Conf.
Yes
Yes
Yes
Yes
Facility Information
Responsible Official Margaret de Gravelle; Environmental Compliance Manager, margaretdegravelle@npsi.us
Type of Operation Seafood processing
What does the facility produce?
Size of Facility
The facility produces fresh and frozen processed seafood products, which includes salmon, halibut, cod, rockfish, and crab.
The facility is approximately19,000 ft2. All processing is done inside the buildings. The only activities conducted outside is the unloading of raw product and loading of finished products.
Number of employees The facility employees approximately 220 people. During processing season, the facility and hours of operation operates two shifts, which cover 24-hour a day, 7-day a week operations.
What waste does the facility generate?
The facility generates fish by-products as a processing waste. The waste flows into a hopper. From the hopper, the waste is transferred to a truck which transfers the material to another facility so it can be further processed into fish meal.
How often does the facility discharge?
When processing, the facility continuously discharges approximately 375,000 gallons per day through a single outfall, which is visually inspected daily.
Do you use in-house or contract out for laboratory analyses? Or both?
The facility analyzes total residual chlorine (TRC), pH, and temperature in-house. All other parameters, such as biochemical oxygen demand (BOD), total suspended solids (TSS), total dissolved solids, settleable solids, oil and grease (O&G), and total ammonia are analyzed by a local contract lab.
The contract lab used by the facility is: Kodiak Seafood Laboratory, Inc. 301 Research Court Kodiak, Alaska 99615 Phone: (907) 481-1700
SECTION II - Observations No Areas of Concern were observed during the site tour.
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SECTION III - Records Review Records may not be in sequential order.
Record: Other - EPA's Integrated Compliance Information System (ICIS) Database
AOC: Yes
Ref #: RA1-RR-012 Reviewed By: Raymond Andrews
Reviewed Date: 07/14/2023
After the inspection, I reviewed data in EPA's ICIS database from July 1, 2018, through June 30, 2023. The ICIS database showed the facility failed to submit one Discharge Monitoring Report (DMR). The facility failed to submit the DMR for the monitoring period ending June 30, 2022, which was due by July 15, 2022.
Record: Other - Facility Response to ADERC Noncompliance Letter
AOC: No
Ref #: RA1-RR-011 Reviewed By: Raymond Andrews
Reviewed Date: 06/08/2023
At the time of inspection, I reviewed facility's response, dated May 29, 2019, to ADEC's Letter of Noncompliance.
Record: Other - Best Management Practices (BMP) Plan Ref #: RA1-RR-010 Reviewed By: Raymond Andrews
AOC: No Reviewed Date: 06/08/2023
At the time of inspection, I reviewed the facility's BMP Plan, dated January 20, 2022. I did not find any issues.
Record: Other - Collective Receiving Water Quality Monitoring Study Ref #: RA1-RR-009 Reviewed By: Raymond Andrews
AOC: No Reviewed Date: 06/08/2023
At the time of inspection, I reviewed the facility's Collective Receiving Water Quality Monitoring Study, dated October 2022.
Record: Other - Alaska Department of Conservation (ADEC) Authorization Letter
AOC: No
Ref #: RA1-RR-008 Reviewed By: Raymond Andrews
Reviewed Date: 06/08/2023
At the time of inspection, I reviewed ADEC's letter of authorization to discharge under new permit, dated June 1, 2021.
Record: Other - Alaska Department of Conservation (ADEC) Noncompliance Letter
AOC: No
Ref #: RA1-RR-007 Reviewed By: Raymond Andrews
Reviewed Date: 06/08/2023
At the time of inspection, I reviewed a letter Noncompliance sent to the facility from ADEC, dated May 3, 2019, stating the facility was in violation of Permit Part 3.7 because foam was visible on the water surface at the base of the boat dock.
Record: Other - Seafloor Monitoring Quality Assurance Project Plan (QAPP)
AOC: No
Ref #: RA1-RR-006 Reviewed By: Raymond Andrews
Reviewed Date: 06/08/2023
At the time of the inspection, I reviewed the Seafloor Monitoring QAPP, dated July 2022. I did not find any issues.
Record: Other - Seafloor Monitoring Report Ref #: RA1-RR-005 Reviewed By: Raymond Andrews
AOC: No Reviewed Date: 06/08/2023
At the time of inspection, I reviewed the facility's 2022 Seafloor Monitoring Report.
Record: Other - pH Meter Calibration Log Ref #: RA1-RR-004 Reviewed By: Raymond Andrews
AOC: No Reviewed Date: 06/08/2023
At the time of inspection, I reviewed the facility's pH Meter calibration log covering the period January 18, 2023, through June 5, 2023. pH Analysis is required 4 times/month (weekly). The pH meter is calibrated prior to collection of each grab sample.
Record: Other - Annual Reports
AOC: No
Ref #: RA1-RR-003 Reviewed By: Raymond Andrews
Reviewed Date: 06/08/2023
At the time of inspection, I reviewed the facility's 2022 Annual Report, dated March 15, 2023.
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Record: Other - Notice of Intent (NOI) Ref #: RA1-RR-002 Reviewed By: Raymond Andrews
AOC: No Reviewed Date: 06/08/2023
At the time of inspection, I reviewed the facility's most recent NOI, dated May 13, 2021.
Record: Other - Quality Assurance Project Plan (QAPP)
AOC: Yes
Ref #: RA1-RR-001 Reviewed By: Raymond Andrews
Reviewed Date: 06/08/2023
At the time of the inspection, I reviewed the facility's Quality Assurance Project Plan (QAPP), dated May 2023.
I noted two deficiencies in the QAPP:
The QAPP did not contain the "Qualification and training of monitoring personnel. The QAPP did not show the number of samples, holding time of pH or the type and number of quality
assurance field samples."
Table 13 gives the number of QC samples for the parameters analyzed by the facility but not those analyzed by the lab. The Lab's QA/QC plan is referenced but that information should be included in the facility QAPP's table. If the lab's QA/QC plan is referenced, it should be included in the QAPP as an Appendix and the Appendix and page number of the appendix should be specifically referenced.
SECTION IV - Sampling Activities No sampling was conducted.
SECTION V - Areas of Concern
Areas of Concern may not be in sequential order. The presentation of Areas of Concern does not constitute a formal compliance determination or violation.
AOC Reference #: RA1-RR-001
Records Review: Other - Quality Assurance Project Plan (QAPP)
Permit Requirement Permit Part 2.9.9.4, "At a minimum, the QAPP shall include...Qualification and training of monitoring personnel."
AOC: The QAPP does not have the "Qualification and training of monitoring personnel."
AOC Reference #: RA1-RR-001
Records Review: Other - Quality Assurance Project Plan (QAPP)
Permit Requirement Permit Part 2.9.9.1, "At a minimum, the QAPP shall include...number of samples...holding times...type and number of quality assurance field samples..."
AOC: The QAPP does not show the number of samples, holding time of pH or the type and number of quality assurance field samples."
AOC Reference #: RA1-RR-012
Records Review: Other - EPA's Integrated Compliance Information System (ICIS) Database
Permit Requirement Permit Part 2.2.4.11.1, "E-Reporting Rule - Phase I (DMRs). The permittee must submit a DMR for each month by the 15th day of the following month. DMRs shall be submitted electronically through NetDMR..."
AOC: The facility failed to submit the DMR for the monitoring period ending June 30, 2022, which was due by July 15, 2022.
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SECTION VI - Closing Conference I held a closing conference with Facility personnel at 03:10 PM (PT) on 06/08/2023. During the closing conference, I discussed my observations and Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. SECTION VII - List of Appendices
1. Photo Log
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APPENDIX 1: Photo Log
All photos were taken by Lead EPA Inspector, Ray Andrews, during the inspection.
Photos were not manipulated beyond minor cropping for sizing and labels or callouts to draw attention to the subject of the photo.
All photos taken during the inspection are included in the Photo Log; however, only photos that support an Area of Concern are included in the inspection report.
P1010789 - Quality Assurance Project Plan (QAPP), cover page, dated May 2023 P1010790 - Quality Assurance Project Plan (QAPP), Title and Approvals page, signed June 2023 P1010791 - Quality Assurance Project Plan (QAPP), Table 6, Project Measurement Quality Objectives (MQOs) P1010792 - Outfall Narrative from NOI, page 1 P1010793 - Outfall Narrative from NOI, page 2 P1010794 - pH Meter Calibration Log, dated January 18, 2023, through June 5, 2023 P1010795 - 2022 Seafloor Monitoring Report, cover page P1010796 - 2022 Seafloor Monitoring Report, Table of Contents page P1010797 - 2022 Seafloor Monitoring Report, Signatory page P1010798 - 2022 Seafloor Monitoring Report, Executive Summary page P1010799 - ADEC Noncompliance Letter, dated May 3, 2019, page 1 P1010800 - ADEC Noncompliance Letter, dated May 3, 2019, page 2 P1010801 - ADEC Letter of Authorization, dated June 1, 2021 P1010802 - Best Management Practices (BMP) Plan, cover page, dated January 10, 2022 P1010803 - Best Management (BMP) Plan, Certification Statement, signed January 13, 2022 P1010804 - Monthly Outfall Water Temperature Log, dated May 2023 P1010805 - Waste Conveyance System Monitoring Log, dated June 5, 2023 P1010806 - Sea Surface and Shoreline Monitoring Observation Log, dated June 5, 2023 P1010807 - NPDES Effluent Sample Data Sheet Chain of Custody, dated June 6, 2023 P1010808 - Facility response to ADEC Letter of Noncompliance, dated May 29, 2019