AKG523000 Alaska Offshore Seafood Processing GP 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.
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 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.
Prince William Sound Baselines Red lines are baselines Waters between shore and baselines are inland waters and are covered by the AKG523000 Permit
Bristol Bay Baselines Red lines are baselines Waters between shore and baselines are inland waters and are covered by the AKG523000 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 22.214.171.124.1 • 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 1.3 • 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 126.96.36.199
Multiple Discharges in One AreaPart 1.3.3 • 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 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 Steller’s eider or spectacled eider Nesting areas of colonies of 1000 or more seabirds
3.1 Protected Areas established in AKG523000 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 http://tidesandcurrents.noaa.gov/curr_pred.html
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 Resource3.5 Areas Covered by Other Permits • A waterbody included in the most recent Final Integrated Water Quality Monitoring Assessment Report. • Most recent report found at http://www.dec.state.ak.us/water/wqsar/waterbody/integratedreport.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 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 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.
4.1 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.
4.2 Admin Covered under AKG52000 • Coverage in the 0.5 nautical mile – 3.0 nm range will continue under AKG520000 until: • Coverage under AKG523000 granted • An individual permit is issued • Coverage under AKG520000 is terminated • Coverage 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 discharge • Existing operators with AKG520000 coverage- • New AKG523000 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 emailed
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, 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 can’t 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.
4.4 Complete NOI Submittal • The 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 Submittal • There are specific submittal requirements that depend on whether the processor is mobile or stationary while processing. Two examples are: • 188.8.131.52 Stationary processor specific requirements • Coordinates of each proposed discharge location • 184.108.40.206 In transit processor specific requirements • Coordinates of the boundary of the area of operation
4.5 NOI Review and Coverage • 220.127.116.11 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 • 18.104.22.168 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 • 22.214.171.124 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
5.1 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 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 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.