Document Ex6e2Kp0M90Y68jnbgQNYYgOg

EPA REGION 10 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 06/09/2023 9:35 AM (PT) Announced: No 06/09/2023 2:50 PM (PT) Access: Granted 46F, Overcast, Drizzly 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 Trident Seafoods Corporation Trident Seafoods - Pillar Mountain Plant 521 Shelikof Street Kodiak, AK 99615 Kodiak Island 57.78619, -152.41806 5303 Shilshole Avenue NW Seattle, Washington 98107 FRS ID Permit Number SIC 110000529599 AKG528825 2092 (Fresh or frozen seafood), 2077 (Animal & marine fats & oils) Lead Inspector: RAYMOND ANDREWS Date: 2023.07.18 09:26:22 -07'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: PETER CONTRERAS Date: 2023.07.20 12:53:51 -07'00' Digitally signed by PETER CONTRERAS Peter Contreras EPA Region 10 contreras.peter@epa.gov (206) 553-6708 Trident Seafoods - Pillar Mountain Plant AKG528825 SECTION I - Opening Conference I arrived at the Trident Seafoods - Pillar Mountain Plant (the "Site" or "Facility"), located at 521 Shelikof Street, Kodiak, Alaska, at 09:35 AM (PT) on 06/09/2023 for an unannounced inspection. I presented my credentials to Mr. Oscar Mares 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 # AKG528825. This report is based on information supplied by Trident 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. NOTE: The facility was not processing at the time of the inspection. Attendees Organization EPA Region 10 Trident Seafoods Attendee Name Raymond Andrews Oscar Mares Title Lead Inspector EHS Specialist Present in Opening Conf. Yes Yes Present in Closing Conf. Yes Yes Facility Information Responsible official? How many outfalls does the facility have? What is the receiving water? How often do you visually inspect the outfall? Are you required to report flow? Size of Facility Shawn Stokes; Director of Environmental Compliance, sstokes@tridentseafoods.com The facility discharges through a single outfall. The facility discharges into Pillar Mountain Bay. The outfall is inspected daily when discharging. The facility is required to report flow and takes meter readings every 24-hours The facility encompasses approximately 2.63 acres. The facility employs approximately 200 employees when operating at full capacity. The facility has scaled down operations for 2023. At its current operating capacity, the Number of Employees facility employs 10 individuals on a semi-permanent basis, while operating with no more and hours of Operation than 20 employees at peak season (July - September). Who analyzes your effluent samples? When at full capacity, the facility operates 24-hours a day, 7-days a week from January through November. The facility analyzes total residual chlorine (TRC), pH, conductivity, and temperature inhouse. All other parameters; 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 When processing, the facility processes whole salmon into salmon filets. Type of Operation The facility is not conducting processing operations this year. At the time of inspection , the facility was being used for storage. 2 of 5 Trident Seafoods - Pillar Mountain Plant AKG528825 SECTION II - Observations No Areas of Concern were observed during the site tour. SECTION III - Records Review Records may not be in sequential order. Record: Other - Best Management Practices (BMP) Plan Annual Review Ref #: RA1-RR-010 Reviewed By: Raymond Andrews AOC: Yes Reviewed Date: 06/09/2023 At the time of inspection, I requested to review the Best Management Practices (BMP) Annual Review. The BMP Plan had a page at the end stating the plan had been reviewed and it was signed and dated by the plant manager; however, the page did not have the required statement that the plan fulfills the requirements set forth in the permit. Record: Spill Prevention Control and Countermeasure (SPCC) Plan AOC: No Ref #: RA1-RR-009 Reviewed By: Raymond Andrews Reviewed Date: 06/09/2023 At the time of the inspection, I reviewed the facility's SPCC Plan, dated January 2018. I did not find any issues. Record: Other - Best Management Practices (BMP) Plan Ref #: RA1-RR-008 Reviewed By: Raymond Andrews AOC: No Reviewed Date: 06/09/2023 At the time of the inspection, I reviewed the facility's BMP Plan, dated August 13, 2021. I did not find any issues. Record: Other - Seafloor Monitoring Quality Assurance Plan (QAPP) Ref #: RA1-RR-007 Reviewed By: Raymond Andrews AOC: Yes Reviewed Date: 06/09/2023 At the time of inspection, I reviewed the facility's Seafloor Monitoring QAPP, dated July 27, 2021. The Seafloor Survey QAPP did not include methods for measuring water depth and tidal stage, and the delivery and archiving of seafloor survey results using field records and notes, survey plans, digital images, and video photography. Record: Other - Seafloor Monitoring Report AOC: No Ref #: RA1-RR-006 Reviewed By: Raymond Andrews Reviewed Date: 06/09/2023 At the time of the inspection, I reviewed the facility's annual Seafloor Monitoring report, dated December 2021. I did not find any issues. Record: Other - Alaska Department of Environmental Conservation (ADEC) Authorization Letter AOC: No Ref #: RA1-RR-005 Reviewed By: Raymond Andrews Reviewed Date: 06/09/2023 At the time of inspection, I reviewed the ADEC Letter of Authorization, dated April 27, 2022. Record: Other - Annual Report AOC: No Ref #: RA1-RR-004 Reviewed By: Raymond Andrews Reviewed Date: 06/09/2023 At the time of inspection, I reviewed the facility's 2022 Annual Report, submitted on February 23, 2023. Record: Other - Receiving Water Quality Monitoring Study AOC: No Ref #: RA1-RR-003 Reviewed By: Raymond Andrews Reviewed Date: 06/09/2023 At the time of inspection, I reviewed the Collective Ambient Receiving Water Quality Monitoring Study, dated April 2022. Record: Other - Notice of Intent (NOI) to Discharge AOC: No Ref #: RA1-RR-002 Reviewed By: Raymond Andrews Reviewed Date: 06/09/2023 At the time of inspection, I reviewed the facility's NOI, dated March 31, 2022. 3 of 5 Trident Seafoods - Pillar Mountain Plant AKG528825 Record: Other - Quality Assurance Project Plan (QAPP) Ref #: RA1-RR-001 Reviewed By: Raymond Andrews AOC: Yes Reviewed Date: 06/09/2023 At the time of inspection, I reviewed the facility's QAPP, dated August 13, 2021. It was last reviewed on October 28, 2022. The QAPP was not written and formatted according to the prescribed references as evidenced by the concerns listed below. At the time of the inspection, the QAPP was missing: The type of sample containers, preservation of samples, and holding times for Total Dissolved Solids; a map indicating the locations of monitoring points; the training records were not in the QAPP; and information on the contract lab used for water analysis. 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 2.9.9.3, " At a minimum, the QAPP shall include...map indicating the location of each sampling point." AOC: The QAPP did not contain a map indicating the locations of monitoring points. 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...Details on number...type of sample containers, preservation of samples, holding times..." AOC: The QAPP did not contain type of sample containers, preservation of samples, and holding times for Total Dissolved Solids. 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: At the time of inspection, the training records were not in the QAPP. AOC Reference #: RA1-RR-001 Records Review: Other - Quality Assurance Project Plan (QAPP) Permit Requirement Permit Part 2.9.9.5, " At a minimum, the QAPP shall include...Name, address, and telephone number of all laboratories used by or proposed to be used by the permittee." AOC: At the time of the inspection, the QAPP did not contain information on the contract lab used for water sample analysis. 4 of 5 Trident Seafoods - Pillar Mountain Plant AKG528825 AOC Reference #: RA1-RR-001 Records Review: Other - Quality Assurance Project Plan (QAPP) Permit Requirement Permit Part 2.9.7, "Throughout all sample collection and analysis activities, the permittee must use DEC-approved Quality Assurance/Quality Control and chain-of-custody procedures, as described in the Requirements for Quality Assurance Project Plans (EPA/QA/R-5, March 2001) at https://www.epa.gov/sites/production/files/201606/documents/r5-final_0.pdf and Guidance for Quality Assurance Project Plans (EPA/QA/G-5, December 2002) at https://www.epa.gov/sites/production/files/2015-06/documents/g5-final.pdf. The QAPP must be prepared in the format specified in these documents." AOC: The QAPP was not written and formatted according to the prescribed references as evidenced by the concerns listed below. AOC Reference #: RA1-RR-007 Records Review: Other - Seafloor Monitoring QAPP Permit Requirement Permit Part 2.9.11.1, "At a minimum, the Seafloor Survey QAPP shall include...Delivery and archiving of seafloor survey results using field records and notes, survey plans, digital images, and video photography." Permit Part 2.9.11.6, "At a minimum, the Seafloor Survey QAPP shall include...Measuring water depth and tide stage." AOC: The Seafloor Survey QAPP did not include methods for measuring water depth and tidal stage, and the delivery and archiving of seafloor survey results using field records and notes, survey plans, digital images, and video photography. AOC Reference #: RA1-RR-010 Records Review: Other - BMP Plan Annual Review Permit Requirement Permit Part 2.10.5.2, "The BMP Plan shall include the following provisions concerning its review...Include a statement that a review has been completed and that the BMP Plan fulfills the requirements set forth in this permit. The statement shall be signed and dated by the facility manager." AOC: The BMP Plan had a page at the end stating the plan had been reviewed and it was signed and dated by the plant manager; however, the page did not have the required statement that the plan fulfills the requirements set forth in the permit. SECTION VI - Closing Conference I held a closing conference with Facility personnel at 02:50 PM (PT) on 06/09/2023. During the 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 5 of 5 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. P1010809 - Quality Assurance Project Plan (QAPP), cover page, dated August 13, 2021 P1010810 - Quality Assurance Project Plan (QAPP), page 2, dated August 13, 2021 P1010811 - 2022 Annual Report, cover page P1010812 - 2022 Annual Report, page 2 P1010813 - ADEC Letter of Authorization, page 1, dated April 27, 2022 P1010814 - ADEC Letter of Authorization, page 2, dated April 27, 2022 P1010815 - ADEC Letter of Authorization, page 3, dated April 27, 2022 P1010816 - ADEC Letter of Authorization, page 4, dated April 27, 2022 P1010817 - Processing Flow Diagram P1010818 - Total Residual Chlorine (TRC) Analysis Form, dated March 4, 2023 P1010819 - pH Analysis Form, dated March 27, 2023 P1010820 - Spill Prevention Control and Countermeasure Plan (SPCC), cover page, dated January 2018 P1010821 - Spill Prevention Control and Countermeasure Plan (SPCC), certification page, dated January 2018 P1010822 - Spill Prevention Control and Countermeasure Plan (SPCC), revisions page, dated January 2018 P1010823 - Best management Practices (BMP) Plan, cover page, dated August 13, 2021 P1010824 - Best management Practices (BMP) Plan, table of contents page, dated August 13, 2021 P1010825 - Best management Practices (BMP) Plan, review and revisions page, dated August 13, 2021