The Gut Boats of Alaska by Peter Bradley/Medium

AK's largest processors have run out of room for burying fish wastes. They are getting a new permit that allows “gut boats” to dump 10 million pounds at sea annually per processor, through a self-monitoring system.

by | June 8, 2024

New policy by DEC permits major shoreside processors to dump thousands of tons of seafood waste at the mouths of bays, rivers and other waterways.

By Peter Bradley at Medium.com
September 6, 2023

Alaska is quietly permitting major on-shore fish processors like Silver Bay Seafoods and Trident Seafoods to dump thousands of tons of seafood waste at the mouths of bays, rivers, sounds, and inlets. Meet the Gut Boats of Alaska.

This photo, from Silver Bay Seafoods (Sitka) permit reports, depicts 35,000 lbs of fish waste being discharged out to sea in Sitka Sound via gut boat on July 15, 2022 — their third dumping trip of that day — part of a new practice being authorized by Alaska DEC for shore-based fish processors in Alaska.

For several years now, these sorts of stories have been bubbling up for Alaska’s largest seafood processors:

“Trident Seafoods has agreed to pay a $300,000 penalty and remove an underwater pile of seafood waste near Sand Point in a settlement with the federal government involving Clean Water Act violations…”
– Alex DeMarban for Anchorage Daily News on March 1, 2018.

“Federal regulators have fined a Sitka seafood processor for allowing its waste pile on the seafloor to balloon to more than double the size allowed by its permit. […] The federal agency accused Silver Bay Seafoods of violating the Clean Water Act by dumping excess blood, oily waste and foam into the water. […] It now appears to have addressed the problem. The company paid a $82,500 penalty and is opting to put a screen on its waste pipe to reduce the volumes it discharges.”
– Jacob Resnick, Coast Alaska (Juneau), on Nov 6, 2019

Both stories linked above, and others besides, were about the underwater piles of fish waste that had accrued in waters beneath the outflow pipes from the processing plants. As far as the rules for these things have stated for years, the seafloor waste isn’t supposed to occupy more than an acre, the annual discharge into that acre isn’t supposed to exceed 10,000,000 pounds, and the chunks that go down are supposed to be 1/2″ or smaller. For some processors, those constraints would have been limiting, had they been adhered to at all. But the constraints are important because the hazards of piling up fish waste have been known for many decades. In a notice on Alaskan Seafood Processing Effluent Limitations Guidelines in 2013, the EPA partially described the problem:

“Fish processing waste piles from land-based facility discharges cover large areas of the seafloor and contain large quantities of solids that negatively affect receiving water quality. These piles range in area, sometimes covering tens of acres. They can grow to many feet thick. (DCN 00201). The waste piles smother benthic (bottom) communities, deplete dissolved oxygen, and cause other harmful impacts on the aquatic ecosystem. In some cases, large waste piles at outfalls (both active and inactive) do not dissipate, even with flushing from tides and strong channel currents. Where discharges have stopped, fish waste piles and their effects can remain for 10 years or more.”

Stories of oversized fish piles beneath plants left me wondering: where do you remove an underwater pile of seafood waste to? and, what happens to the stuff that doesn’t make it through the new screen of the waste outfall pipe?

Where I looked for information

Towards answering the above questions, I used:

I was pretty astonished at what I learned: many of Alaska’s largest processors, in several locations, have responded to running out of room for fish waste below their plants by securing an Alaska General Permit for Offshore Seafood Processors Wastewater Discharge (AKG523000) — allowing them to use gut boats” (also known as gurry boats) to ferry fish waste solids away to designated spots at sea, through a self-monitoring system. The permit links a processing facility to a designated permitted gut boat and a patch of sea to be dumped in, and opens up a new 10,000,000 pound annual dumping allotment for the processor.

So… What’s Happened?

Trident Relocated the Fish Waste Pile at Sand Point

When Trident was asked to clean up the outfall pile by their plant at Sand Point, the agreement that they came up with — as I learned in this waste remediation workplan filed with Alaska DEC — was to dredge up the pile over the course of 45 days and transport it over the course of weeks to a designated area in the center of Popof Strait, right between the 1-mile and 3-mile line:

From the Waste Remediation Work Plan Trident Seafoods — Sand Point Facility Popof Island, AK, Revised Version July 18, 2018.

I corroborated that work-plan with Global Fishing Watch, and located the tracks for the Tug Waldo operating through the summer of 2018, as seen below.

Tracks of the Tug Waldo between July 1, 2018 and September 15, 2018 from Global Fishing Watch, as a pile of fish waste was moved from one place to another.

Meanwhile, Silver Bay Seafoods Left Their Waste Pile Intact, and Began to Dump New Waste At Sea

The pile of fish waste has been dealt with differently in Sitka, according to documents attached to the recent June 2023 wastewater permit renewal.

The permit documents indicate that a seafloor survey “completed on 10/16/2022 found 2.20 acres of Zone of Deposit coverage”. The oversized pile wasn’t shrinking. Included in the permit application was the Seafood Wastewater Source Control Proposal for the plant outfall, including the plan for the oversized pile. Their approach, in practice as in the plan, is to leave the pile as it is, and use gut boats — they call them gurry boats — during peak season. Outside of peak season, waste may be avoided by operating a pet food line for parts of the year, but that will be shut down for peak seasons. They explain: “The material that would normally become the pet food product will be downsized to less than ½” and diverted directly to the gurry vessel, bypassing the facility waste conveyance system and screen plant.”

As they tell it in the Seafood Wastewater Source Control Proposal, Silver Bay Seafoods started using the gut boats in Sitka in 2019, when “A Compliance Order on Consent was issued by the EPA prohibiting the discharge of solid waste through Outfall 001 and requiring annual seafloor monitoring within 90 days of the completion of the salmon processing season until the reduction of the ZOD to less than or equal to 1.0 acres for two consecutive years.” Since then, many thousands of tons of waste have been transported by gut boats under multiple Alaska DEC permits to changing locations in Eastern Channel, and now, farther out, with permission from the EPA.

These images are all vessel tracks, each for a single vessel; in this set, Silver Bay Seafoods’ Sitka processing plant is towards the top right of each image, and the dumping area is at the other end of the vessel tracks. Above-left, Notorious dumping guts during herring season this year, in waters adjacent to shoreline where herring did not end up spawning this year; above-right, Stormbird making 15 runs to the Silver Bay Seafoods dumping grounds between late July and late August this year.
This depicts vessel tracking for Stealth and the Stormbird — working in Sitka, Alaska, in the summers of 2019, 2021, and 2023. Between the two vessel discharge permits owned by Silver Bay 17,459,460 pounds were dumped in 2022; 5,339,342 in 2021, and less than a million pounds in 2019 and 2020. Of note is the very high number listed for plant outfall in 2022–45,002,942 tons of waste was added onto the old pile, as the new waste began to accrue in Eastern Channel.

And so to those questions — where do you remove an underwater pile of seafood waste to, and what happens to the stuff that doesn’t make it through the new screen of the waste outfall pipe at the plant? Well, it turns out that in Alaska, the answer to both questions has become the same: you expand the territory for dumping.

Gut Boats Working Elsewhere in Alaska

These are some of the gut boats that have been working in Alaska in recent years.

This is 2021 in Valdez, where the Resolution II worked as gut boat for the Silver Bay Seafoods plant there. According to records, it dumped 35,085,939 million pounds of fish waste that year, vastly exceeding the 10,000,000 pound limit, as well as the 26,041,655lbs of the previous year.
This summer, New St. Joseph transported waste from the Silver Bay Seafoods plant at Craig, Alaska to this spot in Klawock Inlet.
In summer 2020, the F/V Sea Diamond was dumping at the mouth of Morzhovoi Bay for Silver Bay Seafoods’ False Pass operation — 1,367,941 lbs, the records show.
This shows three years of tracks for dumping runs for Wild Island from the Silver Bay Seafoods plant at Naknek in 2021, 2022 (60,017,922 lbs), and 2023 (27,183,030 lbs).
This photo of gut boat discharge in July 2022 was included in the permit documentation for the SBS Naknek plant.
This shows one summer and an immense amount of dumping traffic from the Royal Pacific and Andronica, working under permits through Bering Select, which makes Cod Liver Oil from byproduct from the Clipper Seafoods Fleet. The numbers appear to be unreported, but those are boats with permits running back and forth to their permitted dumping spot (this image depicts 2021, but this practice has continued to through this summer). On August 24th, 2023, Alaska DEC filed “Compliance Action Documents”, with a letter asserting: “The Department alleges that beginning on or about September 13, 2021 and continuing up until August 23, 2023, at Dutch Harbor, Alaska, Bering Select LLC did unlawfully fail to comply with the conditions of the Alaska Pollutant Discharge Elimination System (APDES) permit.”
This shows the Trident Seafoods gut boat Bountiful, dumping 309,364 lbs of fish waste in 2022, in Golowin Bay in Norton Sound

The above images are not exhaustive, and it appears that more processors are electing to acquire AKG523000 permits to begin dumping waste by boat. The Kodiak Fishmeal Company — which receives the waste from several Kodiak processors — Trident Seafood, Pacific Seafood, Silver Bay Seafoods, Ocean Beauty Seafoods, and North Pacific Seafoods plants — has lined one up that they haven’t used yet. In the Outfall Narrative of their permit application, they wrote it would be used “on a contingency basis in the event that the KFC facility is offline (i.e., unable to process fish wastes), or does not have the capacity to process all of the fish by-products produced during fish processing season”.

It’s an important trend to pay attention to, as many of Alaska’s fish processors are running out of dumping grounds at their current spot. The processors are failing to use the whole product, especially at peak times, and are intensely polluting with fish waste as a result. To highlight the risks of doing this, I’ll quote at length from a 2021 article in the Journal of Environmental Chemical Engineering:

“The environmental concerns associated with disposal of fish wastes into ocean waters include reduced oxygen levels in the seawaters at the ocean bottom; burial or smothering of living organisms; and introduction of disease or non-native and invasive species to the ecosystem of the sea floor. During rainy season, seepage of water through the landfill dump causes additional problems. Nutrients, suspended solids, disinfectants and possible coliform bacteria from the seafood industry effluents affect coastal water quality and hence human life, particularly in the coastal regions. Hypoxia is a condition of low oxygen in the water than can kill fish and other aquatic animals. High level of BOD may cause hypoxia in a receiving environment, leading to anoxia, a condition characterized by an absence of oxygen supply to an organ or a tissue of living organisms. The high levels of nitrogen, phosphorus and FOG may lead to shortage of drinking water, eutrophication (growth of unwanted biota), biotic depletion, algal blooms, habitat destruction, water acidification, disease outbreaks and possible extensive siltation of corals.” — from Venugopal, V., & Sasidharan, A. (2021). Seafood industry effluents: Environmental hazards, treatment and resource recovery. Journal of Environmental Chemical Engineering9(2), 104758. https://doi.org/10.1016/j.jece.2020.104758

To illustrate the scale of the issue, a search of EPA’s ECHO tool for facilities belonging to a grouping of major seafood processors in Alaska returns 83 facilities, 55 of them with current violations.

Many of those violations have to do with things like exceeding permitted seafloor area, exceedences of (usually) 10,000,000 lb dumping allowances, outflow lines breaking near shore, or problems and gaps with self-reporting. I’m writing this to flag that many major processing plants appear to be running in a near-chronic state of violation of regulations… and gut boats are increasingly part of it.

After diving deep into the recesses of the EPA and Alaska DEC websites this week, I’ve realized that regulatory practice around this has changed — without a whisper — to more totally accommodate processors in extreme wasting during peak season, and to make allowances for violations.

Instead of one permit for one outfall pipe, a processor can now have multiple permits for multiple gut boats. Suddenly, a new immensity of fish waste is being allowed to be produced and dumped, farther from the plants but still in nearshore waters, sapping oxygen from surrounding waters while adding other chemical byproducts to the mix, spreading ill effects, promoting new zones of oxygen depleted waters.

This emergent dumping practice begs the question: is it really bad, or simply offal?

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About Laine

Laine Welch has covered the Alaska fish beat for print and radio since 1988. She also has worked “behind the counter” at retail and wholesale seafood companies in Kodiak and on Cape Cod.

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