Informational Meeting for the Proposed Final Permit May 10, 2011

Meeting Agenda Introduction Purpose of Meeting Brief Permit Issuance History Discuss Permit Questions about the Permit

Introduction Shawn Stokes-Program Manager-Permitter Michelle Bonnet-Program Manager Chris Foley-Compliance Program Manager

Informational Meeting Purpose Discuss the proposed permit with potential permittees. Not a Public Hearing. No comments on permit accepted. Only changes to the permit allowed are minor modifications, such as from a typographical error.

Permit Issuance History

1.0 Permit Authorization

Mobile Processors and Stationary Processors. Starts at 0.5 nautical miles from shore. Ends at 3.0 nautical miles from shore or baseline, whichever is greater. NPDES Permit AKG starts at 3.0 nautical miles from shore or baseline whichever is greater. Only operators of facilities that discharge more than 1,000 pounds per day and 30,000 pounds per calendar year of seafood waste.

Baseline

Prince William Sound Baselines Red lines are baselines Waters between shore and baselines are inland waters and are covered by the AKG Permit

Bristol Bay Baselines Red lines are baselines Waters between shore and baselines are inland waters and are covered by the AKG permit.

Mixing Zone Authorization Part 1.2 Maximum mixing zone size that will be authorized is the area of a 100 foot radius circle centered on the outfall or discharge pipe. The authorized mixing zone size may be smaller in size if the receiving water warrants a reduced size. The mixing zone size determination criteria are listed in Permit Part If a mixing zone is not authorized water quality standards have to be met in the receiving water at point of discharge.

Zone of Deposit Allowance Part 1.3 A deposit of seafood waste may be allowed for stationary processors between 0.5 and 1.0 nautical miles from shore. Maximum area of deposit allowed per single location, 1.0 acre. A smaller area of deposit may be authorized if receiving water conditions warrant a reduced size. The criteria for the zone of deposit area determination are in Permit Part

Multiple Discharges in One Area Part Areas with multiple operators may require limits on the amount of seafood waste discharged in individual authorizations. Regulate the cumulative amount of waste discharged to the receiving water. Prevent cumulative zones of deposit in the area. Individual permits may be required for certain waters.

2.0 Authorized Discharges

Seafood Processing waste that has been treated to 0.5 inches or smaller in all dimensions. The permit establishes a performance standard of treatment. The permit does not require a specific treatment technology to meet the performance standard. Discharge to hydrodynamically energetic waters only.

2.0 Authorized Discharges Wash-down water with EPA approved disinfectants. Sanitary wastewater (blackwater) from a Marine Sanitation Device. Graywater from galleys, bath, showers, and sinks. Other wastewater Seafood catch transfer water Scrubber water Refrigerated seawater

3.0 Excluded Areas

3.0 Areas Excluded from Coverage Areas excluded from general permit coverage Protected At-risk Special Degraded Areas not listed as excluded in the final permit State Parks and State Marine Parks Small water bodies Appendix E provides a partial list of excluded areas. Appendix F provides maps of excluded areas.

3.1 Protected Water Resources continued from AKG52000 Permit State Game Refuges and Sanctuaries State Designated Critical Habitat Areas National Parks, Preserves, and Monuments National Wilderness Areas National Wildlife refuges Critical Habitat Areas and important habitat areas for Stellers eider or spectacled eider Nesting areas of colonies of 1000 or more seabirds

3.1 Protected Areas established in AKG Critical Habitat Areas for Northern Sea Otter, SW Alaska Distinct Population Segment Rookery or terrestrial haulout of the Pacific Walrus

3.2 At-Risk Water Resources Areas with water depths less than 10 fathoms at Mean Lower Low Water that have or are likely to have poor flushing. Poor flushing is average currents less than 0.33 knots within 300 feet of outfall. Stationary operators shall provide documentation of adequate flushing with the NOI. NOAA Tides & Current Website with Tidal Predictions

3.3 Special Water Resources Lost Harbor, Akun Island Orca Inlet Uncooked seafood waste discharge from November to March Living Substrates Submerged aquatic vegetation, kelp, eelgrass The territorial seas surrounding St. Paul and St. George Aleutian Islands Coral Habitat Protection Areas

3.4 Degraded Water Resource 3.5 Areas Covered by Other Permits A waterbody included in the most recent Final Integrated Water Quality Monitoring Assessment Report. Most recent report found at tegratedreport.htm tegratedreport.htm The permit does not authorize discharges to waters covered by other permits.

Authorization to Discharge to an Excluded Area Waiver provisions not continued from AKG Authorization to discharge to an excluded area will require a Major modification to the permit. Major modifications of the permit require a public notice of the proposed permit modifications. Minimum 30 day public comment period.

Authorization to Discharge to an Excluded Area Appendix H is the mechanism whereby discharges to otherwise excluded areas are proposed. Appendix H will provide the minimum additional conditions and limits to be included in the written authorization.

Authorization to Discharge to an Excluded Area An operator who requests a Major modification to the permit is required to submit substantial information. The fact sheet (Part 6.1.2) describes the type of information that should be submitted when requesting a modification to the permit.

4.0 Application to be Permitted

4.1 Submittal of a Notice of Intent Timely and Complete Notice of Intent (NOI) required. Preferred method of application is Electronically through Water Online Application System. Alternatively, a NOI form can be completed electronically, signed, scanned and then both the scanned and electronic version submitted to DEC. New authorization numbers will be issued to covered facilities.

Water Online Application System

4.2 Admin Covered under AKG52000 Coverage in the 0.5 nautical mile – 3.0 nm range will continue under AKG until: Coverage under AKG granted An individual permit is issued Coverage under AKG is terminated Coverage under AKG will continue for shorebased operations and for vessels operating between shore and 0.5 nm from shore even after AKG coverage is granted.

4.3 Timely Notice of Intent (NOI) New operators – 90 days prior to discharge Existing operators with AKG coverage- New AKG NOI due no later than December 1, 2011 Material changes Updated NOIs to DEC before changes occur Updated NOIs can be filed on-line If not filed on-line, updated signed NOIs can be ed

4.3.5 Reapplication NOI Permit will expire 5 years after effective date Reapplication NOI is due 90 days before expiration of the permit – Approximately no later than April 1, Only operators with coverage under AKG that submit complete reapplication NOIs before the expiration date, can be granted administratively extended permit coverage under the expiring permit. Authorization cant be granted to new operator under an expired permit.

4.3.5 Reapplication NOI Supplemental information may be required with reapplication NOI. The department will provide reasonable notice if supplemental information is required. Supplemental information may be used to support and refine mixing zone determinations or zone of deposit determinations.

Permit Timeline – possible scenario

4.4 Complete NOI Submittal The AKG NOI requires additional information as compared to an AKG NOI. There are NOI instructions included with the NOI form. To expedite the NOI review, the NOI attachment should be submitted via a Microsoft Excel spreadsheet.

4.4 Complete NOI Submittal There are specific submittal requirements that depend on whether the processor is mobile or stationary while processing. Two examples are: Stationary processor specific requirements Coordinates of each proposed discharge location In transit processor specific requirements Coordinates of the boundary of the area of operation

4.5 NOI Review and Coverage Mixing Zone size determination Effects the discharge might have on uses of the receiving water Flushing and mixing characteristics Cumulative effects of multiple mixing zones

4.5 NOI Review and Coverage Zone of Deposit area determination Effects the discharge might have on uses of the receiving water Flushing and mixing characteristics Cumulative effects of multiple zones of deposit Only required for stationary processors operating between 0.5 and 1.0 nm from shore

4.5 NOI Review and Coverage Amount of seafood processing waste authorized may be limited by conditions of the receiving water. The Department has three options on completion of the NOI review: Transmit coverage determination with mixing zone size determination, zone of deposit area determination, and amount of seafood processing waste authorized. Notify operator of incomplete NOI Deny coverage under the general permit

5.0 Limitations and Requirements

5.1 Effluent Limitations Maximum amount of seafood waste authorized may be limited by conditions at the proposed discharge location or area of operation. Maximum amount authorized will be the smaller of the amount in the NOI or the amount in a written authorization. Stationary processor, 0.5 nm to 1.0 nm, 3.3 million pounds annually, maximum per single location

5.1.3 Effluent Monitoring Table 2 lists monitoring requirements of the seafood processing waste discharge to begin in January Analysis will need to be on the processing facility due to holding times. DEC intends to host industry workshops in 2012 and 2013.

5.1.3 Effluent Monitoring Table 3 presents the effluent monitoring and analysis requirements when within 20 nautical miles of an airport hub. Analysis performed at a contract laboratory Airport hubs identified in Appendix J

5.1.3 Effluent Monitoring Table 4 provides the marine sanitation device effluent monitoring and analysis requirements. Table 5 provides the graywater discharge monitoring and analysis requirements. Only required when within 20 nautical miles of a DEC certified laboratory capable of microbiological analysis. DEC certified labs identified in Appendix J

5.1.4 Receiving Water Monitoring Table 6 present the receiving water monitoring and analysis requirements. Some analytical testing will need to be performed on the sampling vessel or the processing facility due to holding times. 2 sample locations per monitoring event, 2 depths per sample location

5.1.4 Receiving Water Monitoring Table 7 provides the receiving water monitoring requirements when within 20 nautical miles of an airport hub. Analysis at contract laboratory. Airport hubs identified in Appendix J Table 8 provides the receiving water monitoring requirements when within 20 nautical miles of a DEC certified drinking water laboratory. Analysis at certified lab. DEC certified labs identified in Appendix J

5.1.5 Quality Assurance Project Plan Quality Assurance Project Plan required to be developed and implemented Generic Seafood QAPP development

5.1.6 Receiving Water Criteria Table 9 provides a summary of the water quality criteria that may be exceeded in a mixing zone, if authorized. Table 9 provides a summary of the residue water quality criteria that may be exceeded in a zone of deposit, if allowed.

5.1.8 Waste Conveyance System Daily visual inspection Daily log of inspection Attachment B Grinder and Waste Conveyance Inspection Log Non-compliance shall be reported in accordance with Part 3.5 of Appendix A, which is with the annual report.

5.1.9 Grinder System Daily inspection Daily log of inspection Attachment B Grinder and Waste Conveyance Inspection Log Pictures of grinder in action at least 1 time per month Non-compliance shall be reported in accordance with Part 3.5 of Appendix A, which is with the annual report.

Outfall System Pictures of the receiving water in the area of the outfall system at least one time per month. No discharges from broken outfall after 10 days. Broken outfalls shall be reported to DEC within 24 hours.

Other Wastewaters Nuisance Discharges Incidental Foam and Scum associated with seafood catch transfer water shall be minimized to the extent practicable. Part of BMP plan. Attractive nuisance situations shall be avoided. BMPs shall be developed and implemented.

6.0 Specific Requirements

6.1 Best Management Practices Plan requires specific management practices and standard operating procedures for a number of specific discharges and activities Certification of BMP implementation submitted to DEC within 60 days of authorization Certification that the BMP has been reviewed shall be submitted to DEC whenever an updated NOI is submitted. Attachment F BMP Certification Form

6.2 Annual Report AKG Annual Report requires additional information as compared to a AKG Annual Report One daily location, in decimal degrees, while processing Daily location information can be presented as tracks on a chart. Attachment E Annual Report Form Annual Report Attachment should be submitted as a Microsoft Excel document to expedite the review.

6.2 Annual Report Outfall 001 Seafood Processing Waste Outfall Monitoring Report Outfall 002 Marine Sanitation Device Effluent Monitoring Report Outfall 003 Graywater Monitoring Report Receiving Water Monitoring Report

6.3 Seafloor Survey Requirements Seafloor surveys required when a stationary processor discharges seafood processing waste for seven or more days (168 hours) at a single location per calendar year. The Survey Protocol provided with the permit (Appendix D) applies when a diver performs the seafloor survey. Other survey methods are allowed and the protocol can be modified to accommodate other methods. DEC has to approve modifications to the protocol

6.3 Seafloor Survey Surveys shall be conducted within 90 days of the end of discharge, weather and conditions permitting. The survey report shall be submitted within 60 days of the survey being completed.

Modification of Survey The seafloor survey monitoring requirement may be modified or reduced. Specific submittal requirements with a reduction of monitoring request.

6.4 Sea Surface Monitoring Daily monitoring of the sea surface. Capture photos of sea surface at least once per month. Attachment C Sea Surface Monitoring Log.

Industry Workshops Industry workshops planned for January 2012 and Location of workshops – to be determined.