StarKist Samoa Co.
Outcome
StarKist Samoa agreed to pay $6.5 million civil penalty and install wastewater treatment system upgrades projected to reduce annual discharges of nitrogen, phosphorus, oil/grease, and suspended solids into Pago Pago Harbor by at least 85%, removing over 13 million pounds of pollutants annually.
Details
StarKist Samoa Co. — Multi-Statute Violations at Pago Pago Harbor (2017)
Outcome: StarKist Samoa agreed to pay $6.5 million civil penalty ($3.9 million to United States, $2.6 million to American Samoa government) and install wastewater treatment system upgrades projected to reduce annual discharges into Pago Pago Harbor by at least 85%, removing over 13 million pounds of combined pollutants annually.
StarKist Samoa Co., a wholly owned subsidiary of StarKist Co. (itself a subsidiary of Korea's Dongwon Industries), operates a tuna processing facility at Pago Pago Harbor in Atu'u village on the island of Tutuila in American Samoa. The facility, one of the largest private employers in the territory, generated documented violations across multiple federal environmental statutes over a period of years.
Clean Water Act violations included: discharge of excess nutrients (total nitrogen, ammonia, phosphorus) in violation of NPDES permit limits; discharge of industrial stormwater into Pago Pago Harbor without a required CWA permit; and failure to implement a proper Spill Prevention, Control and Countermeasure (SPCC) plan for above-ground storage tanks. Clean Air Act violations centered on failure to operate and maintain ammonia, butane, and chlorine systems in compliance with the General Duty Clause — a worker and community safety provision. RCRA and EPCRA violations were also cited.
The settlement, announced September 2017, required payment of the $6.5 million civil penalty plus $88,000 for emergency response equipment donated to local American Samoa responders. Wastewater treatment system upgrades required under the settlement are projected to reduce annual discharges of total nitrogen, phosphorus, oil and grease, and total suspended solids by at least 85%, removing more than 13 million pounds of pollutants per year from Pago Pago Harbor. A revised settlement was reached in subsequent years after StarKist failed to meet certain compliance deadlines, resulting in additional fines.
Primary Source: StarKist Clean Water Act, Clean Air Act, RCRA and EPCRA Settlement | US EPA
How Crucible Prevents This
StarKist's violations span five environmental statutes — a multi-statute enforcement pattern that results from siloed compliance management. Crucible's cross-statute compliance calendar, tracking NPDES permit deadlines, SPCC plan reviews, CAA General Duty Clause requirements, and RCRA hazardous waste management obligations in a single unified system, would have prevented the simultaneous regulatory exposure across CWA, CAA, and RCRA. The absence of an SPCC containment plan for above-ground storage tanks is a foundational compliance omission that a session-init protocol check would catch.
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