AKG523000 Alaska Offshore Seafood Processing GP

AKG523000 Alaska Offshore Seafood Processing GPInformational Meeting for theProposed Final PermitMay 10, 2011

Meeting AgendaIntroductionPurpose of MeetingBrief Permit Issuance HistoryDiscuss PermitQuestions about the Permit

IntroductionShawn Stokes-Program Manager-PermitterMichelle Bonnet-Program Manager Chris Foley-Compliance Program ManagerInformational Meeting PurposeDiscuss 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 History1.0 Permit Authorization1.0 Permit AuthorizationMobile 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 AKG524000 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

Baseline

Prince William Sound BaselinesRed lines are baselinesWaters between shore and baselines are inland waters and are covered by the AKG523000 Permit

Bristol Bay BaselinesRed lines are baselinesWaters between shore and baselines are inland waters and are covered by the AKG523000 permit.

Mixing Zone Authorization Part 1.2Maximum 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 4.5.2.2.1 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 1.3A 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 4.5.2.3

Multiple Discharges in One AreaPart 1.3.3Areas 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 Discharges2.0 Authorized DischargesSeafood 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 DischargesWash-down water with EPA approved disinfectants.Sanitary wastewater (blackwater) from a Marine Sanitation Device.Graywater from galleys, bath, showers, and sinks.Other wastewaterSeafood catch transfer waterScrubber waterRefrigerated seawater3.0 Excluded Areas3.0 Areas Excluded from CoverageAreas excluded from general permit coverageProtectedAt-riskSpecialDegradedAreas not listed as excluded in the final permitState Parks and State Marine ParksSmall water bodiesAppendix E provides a partial list of excluded areas.Appendix F provides maps of excluded areas.3.1 Protected Water Resources continued from AKG52000 PermitState Game Refuges and SanctuariesState Designated Critical Habitat AreasNational Parks, Preserves, and MonumentsNational Wilderness AreasNational Wildlife refugesCritical Habitat Areas and important habitat areas for Stellers eider or spectacled eiderNesting areas of colonies of 1000 or more seabirds

3.1 Protected Areas established in AKG523000Critical Habitat Areas for Northern Sea Otter, SW Alaska Distinct Population SegmentRookery or terrestrial haulout of the Pacific Walrus

3.2 At-Risk Water ResourcesAreas 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 http://tidesandcurrents.noaa.gov/curr_pred.html 3.3 Special Water ResourcesLost Harbor, Akun IslandOrca InletUncooked seafood waste discharge from November to MarchLiving SubstratesSubmerged aquatic vegetation, kelp, eelgrassThe territorial seas surrounding St. Paul and St. GeorgeAleutian Islands Coral Habitat Protection Areas3.4 Degraded Water Resource3.5 Areas Covered by Other PermitsA waterbody included in the most recent Final Integrated Water Quality Monitoring Assessment Report.Most recent report found at http://www.dec.state.ak.us/water/wqsar/waterbody/integratedreport.htmThe permit does not authorize discharges to waters covered by other permits.Authorization to Discharge to an Excluded AreaWaiver provisions not continued from AKG520000.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 AreaAppendix 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 AreaAn 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 Permitted4.1 Submittal of a Notice of IntentTimely 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 AKG52000Coverage in the 0.5 nautical mile 3.0 nm range will continue under AKG520000 until:Coverage under AKG523000 grantedAn individual permit is issuedCoverage under AKG520000 is terminatedCoverage under AKG520000 will continue for shorebased operations and for vessels operating between shore and 0.5 nm from shore even after AKG523000 coverage is granted.

4.3 Timely Notice of Intent (NOI)New operators 90 days prior to dischargeExisting operators with AKG520000 coverage-New AKG523000 NOI due no later than December 1, 2011

Material changesUpdated NOIs to DEC before changes occurUpdated NOIs can be filed on-lineIf not filed on-line, updated signed NOIs can be emailed 4.3.5 Reapplication NOIPermit will expire 5 years after effective dateReapplication NOI is due 90 days before expiration of the permit Approximately no later than April 1, 2016.Only operators with coverage under AKG523000 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 NOISupplemental 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 SubmittalThe AKG523000 NOI requires additional information as compared to an AKG520000 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 SubmittalThere are specific submittal requirements that depend on whether the processor is mobile or stationary while processing. Two examples are:4.4.9.4 Stationary processor specific requirementsCoordinates of each proposed discharge location4.4.9.5 In transit processor specific requirementsCoordinates of the boundary of the area of operation

4.5 NOI Review and Coverage4.5.2.2 Mixing Zone size determinationEffects the discharge might have on uses of the receiving waterFlushing and mixing characteristicsCumulative effects of multiple mixing zones

4.5 NOI Review and Coverage4.5.2.3 Zone of Deposit area determinationEffects the discharge might have on uses of the receiving waterFlushing and mixing characteristicsCumulative effects of multiple zones of depositOnly required for stationary processors operating between 0.5 and 1.0 nm from shore4.5 NOI Review and Coverage4.5.2.4 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 NOIDeny coverage under the general permit5.0 Limitations and Requirements5.1 Effluent LimitationsMaximum 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 MonitoringTable 2 lists monitoring requirements of the seafood processing waste discharge to begin in January 2013.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 MonitoringTable 3 presents the effluent monitoring and analysis requirements when within 20 nautical miles of an airport hub. Analysis performed at a contract laboratoryAirport hubs identified in Appendix J5.1.3 Effluent MonitoringTable 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 MonitoringTable 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 location5.1.4 Receiving Water MonitoringTable 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 JTable 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 PlanQuality Assurance Project Plan required to be developed and implementedGeneric Seafood QAPP development5.1.6 Receiving Water CriteriaTable 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 SystemDaily visual inspectionDaily log of inspectionAttachment 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 SystemDaily inspectionDaily log of inspectionAttachment B Grinder and Waste Conveyance Inspection LogPictures 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.

5.1.10 Outfall SystemPictures 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.5.1.11 Other Wastewaters5.1.12 Nuisance DischargesIncidental 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 Requirements6.1 Best Management Practices Plan6.1.5.3.5 requires specific management practices and standard operating procedures for a number of specific discharges and activities.6.1.5.4.1 Certification of BMP implementation submitted to DEC within 60 days of authorization.6.1.5.4.2 Certification that the BMP has been reviewed shall be submitted to DEC whenever an updated NOI is submitted.Attachment F BMP Certification Form6.2 Annual ReportAKG523000 Annual Report requires additional information as compared to a AKG520000 Annual Report.6.2.2.3.2 One daily location, in decimal degrees, while processing.6.2.2.5.2 Daily location information can be presented as tracks on a chart.Attachment E Annual Report FormAnnual Report Attachment should be submitted as a Microsoft Excel document to expedite the review. 6.2 Annual ReportOutfall 001 Seafood Processing Waste Outfall Monitoring ReportOutfall 002 Marine Sanitation Device Effluent Monitoring ReportOutfall 003 Graywater Monitoring ReportReceiving Water Monitoring Report 6.3 Seafloor Survey RequirementsSeafloor 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 protocol6.3 Seafloor SurveySurveys 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.

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

Industry WorkshopsIndustry workshops planned for January 2012 and 2013.

Location of workshops to be determined.